Many international guidelines have been published suggesting ways to craft an effective anti-corruption compliance program. One of the common features in most, if not all, of these guidelines, is the importance of the "tone at the top" or need for high level management buy-in and communication of the importance of anti-corruption compliance. What concrete steps can companies take to set an appropriate "tone at the top"? How can a business effectively establish and implement an anti-corruption compliance program either in the absence of an appropriate "tone at the top" or even when some of the senior management team are themselves involved in corrupt activities?