Not everyone who has operated in Asia or the former Soviet States is corrupt.
Additionally it is (even if they so desired) increasingly difficult for clubs to operate in a manner in which they may have done in the past. There's also legislation which now makes companies liable for the actions of their employees (2010 Bribery Act). Therefore I'd be extremely surprised if Everton or its employees were involved in such.
I suspect the problem today lies with agents and what they do with their fees rather than the club's themselves.
My earlier point about Everton not just rolling over on agents fees suggests they are aware of the potential for wrong doing and are not prepared to allow it to happen within their control.
The reason I have advocated a 'Corporate Compliance Director' for EFC is thus:
1. Needs to be director level to ensure that legal + sporting compliance is strategic to the company and the person nominated has the seniority to act directly on behalf of the shareholders.
2. HR and similar may not have seniority to act against director level employees - where necessary
3. The definitions are being deliberately circumnavigated (e.g. Allardyce quotes on camera) and the issue is that Club Employees (scouts and or senior player acquisition parties may be unduly influenced for cash - and act contrary to the best interests of the club - under the influence of third parties). This is a strategic problem for EFC
A dedicated independent director answers direct to shareholders and the CEO.
It puts a break or is designed to make it very difficult for any EFC employee to act against the interests of EFC - in favour of third party interests.
This is my view and I have thought long and hard about it.
