Welcome back to the podcast, bribe, swindle, or steel. I'm Alexandra Ragi, and my guest today is Lisa Miller.

Lisa is the Integrity Compliance Officer at the World Bank Group in Washington, D.C. Lisa, thanks so much for joining me.

Thank you, Alexandra. I very much appreciate this opportunity.

You have a wide range of responsibilities at the bank, but I'd really like to focus today on the

role of SMEs, small and medium-sized enterprises. You work with them in a number of capacities,

but I think what people are going to find really interesting is the

role you play in rehabilitating an SME after they've had a problem with the bank. Can you describe

that program and your role in it? Our office gets involved with companies as well as individuals, but focusing on SMEs, we'll focus on

the companies. So we get involved with companies after they have been sanctioned by the World Bank

Group, meaning that they have been found to have engaged in fraud or corruption under a World Bank

Group finance project. And they've gone through the administrative sanction system

at the World Bank Group, or they may have entered into a settlement agreement. But once they've

gone through that process or entered into a settlement agreement, if their sanction, whether it's

a debarment or a conditional non-debarment, includes conditions for release from that sanction, whether it's a debarment or conditional non-debarment, includes conditions for release from

that sanction, those companies automatically come into our portfolio. So then it is our job to work

with those companies to help them meet their conditions for release. And in most cases, those conditions will require a company

to implement an integrity compliance program that is consistent with 11 principles that we have set out

in our World Bank Group Integrity Compliance Guidelines. And so whether it's an SME or a larger company,

the expectation on our part is that the company

will implement a program that's appropriate to its own circumstances, including its size,

as well as its own risk profile that is consistent with those guidelines.

And how the program is developed and implemented should be very specific to, tailored to, that

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