eacffpc ethics and integrity training manual

THE EASTERN AFRICA CUSTOMS AND FREIGHT FORWARDING PRACTICING CERTIFICATE

(EACFFPC)

ETHICS AND INTEGRITY

OCTOBER 2012 EDITION

THE FEDERATION OF EAST AFRICAN FREIGHT FORWARDERS ASSOCIATIONS (FEAFFA)

In Collaboration with

EAST AFRICA REVENUE AUTHORITIES

With Support from

TRADEMARK EAST AFRICA (TMEA)

FOREWORD

In 2006 and with donor support the national associations of freight forwarders in East

African Community (EAC) member countries, working under their umbrella organization –

the Federation of East African Freight Forwarders Association (FEAFFA), partnered with

Revenue Authorities of EAC member states to launch a formal training program for

practitioners in the customs clearing and freight forwarding sector. This program culminated

into the award of a certificate after four-six months of intensive training that equipped the

practitioners with technical skills and professional ethics in line with emerging trends in the

industry. This certificate – the East Africa Customs and Freight Forwarding Practicing

Certificate (EACFFPC) was intended to be one of the main criteria for licensing of Customs

Clearing Agents (CFA) by the Revenue Authorities in EAC. The launched formal training

program consisted of a training curriculum and the training materials. This was the inaugural

formal training program developed in this sector and was packaged in such a way as to

provide a strong foundation for effective training. The program has just been evaluated and

the program has been found highly successful in producing competent practitioners.

The curriculum has just been reviewed and updated to accommodate the industry changing

environment. It has also been further aligned to the East African Customs training program.

This has therefore necessitated the rewriting of the training materials to make them

respond to the reviewed curriculum’s skills requirements and its demands on practitioners’

ethical and professional disposition. The training materials development process has been

possible with the support of Trade Mark East Africa (TMEA) which has provided the

necessary financial resources.

ACKNOWLEDGEMENTThe Curriculum Implementation Committee (CIC) is grateful to the National Revenue

Authorities and the National Freight Forwarders Associations for accepting to release their

staff and members to carry out the development of the training materials. CIC

acknowledges the FEAFFA secretariat for excellent co-ordination of the process of materials

development and the eventual compilation of the manuals.

Special thanks go to William Ojonyo who steered the team of experts that developed the

materials.

The tremendous support provided by our development partner, Trade Mark East Africa

(TMEA), cannot go unnoticed bearing in mind that they provided all financial support that

culminated into the development of the training materials.

A big THANK YOU to the following individual subject experts who took their valuable time

and wide experience in developing this BASIC MANAGEMENT MODULE- ETHICS AND

INTEGRITY UNIT that have gone down the history lane.

1. Carol Watila.2. John Mathenge.3. Margaret Nabukenya.4. Rose Wangwe.5. Vicent Mary Kamanguza.

…………………………………………………………………………….. Lillian Umuhire RugambwaChairpersonCurriculum Implementation Committee (CIC)

TABLE OF CONTENT

TABLE OF CONTENT..............................................................................................................2

ETHICS AND INTEGRITY.........................................................................................................4

INTRODUCTION.................................................................................................................... 4

DEFINITION OF TERMS..........................................................................................................4

SESSION OBJECTIVES.........................................................................................................4

ETHICS...............................................................................................................................5

PROFESSIONAL ETHICS......................................................................................................5

INTEGRITY......................................................................................................................... 6

CORRUPTION.....................................................................................................................7

MORALITY.........................................................................................................................9

FRAUD.............................................................................................................................11

ETHICS AND INTEGRITY FROM A GLOBAL PERSPECTIVE.....................................................14

SESSION OBJECTIVES.......................................................................................................14

INTRODUCTION...............................................................................................................14

THE WORLD CUSTOMS ORGANIZATION (WCO) REVISED ARUSHA DECLARATION ON ETHICS.............................................................................................................................14

OTHER CONVENTIONS AND PROTOCOLS ON CORRUPTION...........................................17

ETHICS AND INTEGRITY IN THE NATIONAL CONTEXT......................................................17

CORRUPTION......................................................................................................................19


INTRODUCTION...............................................................................................................19

CAUSES AND TYPES OF CORRUPTION.............................................................................19

CORRUPTION WITHIN THE CLEARING AND FORWARDING SECTOR................................22

CONSEQUENCES OF CORRUPTION..................................................................................22

STRATEGIES FOR PREVENTING CORRUPTION WITHIN THE C&F INDUSTRY....................23

BENEFITS OF UPHOLDING INTEGRITY.............................................................................24

FRAUD.................................................................................................................................26


TYPES OF FRAUD.............................................................................................................26

TAX EVASION...................................................................................................................27

CONSEQUENCES OF FRAUD AND TAX EVASION..............................................................27

ETHICAL BEHAVIOR.........................................................................................................29


INTRODUCTION...............................................................................................................29

FUNDAMENTALS OF WORK ETHICS.................................................................................30

PRINCIPLES OF ETHICAL POWER.....................................................................................31

CREATING A C&F ETHICAL ENVIRONMENT.....................................................................32

FEAFFA Code of Ethics.....................................................................................................33

CORRUPTION RISK ASSESSMENT AND MANAGEMENT.......................................................35

IMPORTANCE OF RISK ASSESSMENT TO THE MANAGEMENT.........................................35

STEPS FOR CORRUPTION RISK ASSESSMENT...................................................................36

HANDLING ETHICAL DILEMMAS......................................................................................38

CASE STUDY:...........................................................................................................................40

References..........................................................................................................................42

1. The Power of Ethical Management by Dr Norman Vincent Peale & Kenneth Blanchard, 2011…...................................................................................................................

.....................................................................................................................................42

2. The Integrity Advantage, Adrian Gostick & Dawn Telford Todd Gittin, Gibbs Smith Publisher ISBN 1-58685-246-9.........................................................................................42

3. Business Ethics: A philosophical Reader (Newyork) Macmillan Publishing, 1993........42

4. International Business by McGraw-Hill/Irwin, 5th Edition, 2005..................................42

5. Asian Pacific Development Journal Vol 7, No 2, “Corruption: Causes, consequences and cures................................................................................................................................

.....................................................................................................................................42

6. Ethical Business Practice..............................................................................................42

ANNEX 1..............................................................................................................................43

MODULE 3: BASIC MANAGEMENT SKILLS

UNIT V: ETHICS AND INTEGRITY

INTRODUCTION;

‘When wealth is lost, nothing is lost; when health is lost, something is lost; but when character is lost, all is lost’. Billy Graham

The impact of globalisation in the 21st century demands that professionals take lead in providing direction and guidance by establishing strong high morals, discipline, Practices and ethical values in all sectors. Customs agents industry in adherence to this has formulated EAC training materials that will foster, nurture, and sow a value system that will build an integrated region to meet the global demands.

The Ethics and Integrity module has been formulated by incorporating the spirit and principles of the FEAFFA Constitution. The fact that the module will be accessed regionally in the EAC that is comprised of diverse races and religious beliefs is a gift and an advantage to be utilized in building a united, just, and progressive region that will adhere strongly to the principles of good ethical practices.

This unit will provide vast knowledge on ethics, integrity and corruption with both theoretical and practical approaches on enhancement of integrity and elimination of corruption. It will also equip the participants with knowledge, skills and attitudes that will enable them uphold ethical values required in the C&F industry while providing services to customers.

A Customs Agent refers to any person who is engaged in providing any service, either directly or indirectly, concerning the clearing and forwarding operations, in any manner to any other person and includes a consignment agent. To effectively discharge their functions, a high level of integrity is critical. Lack of it impacts negatively on the efficiency of business, increases costs, leads to loss of government revenue and causes lapse to security and safety.

TOPIC 1: DEFINITION OF TERMS

2 HOURS

SESSION OBJECTIVESa. To create an understanding of the different terms in the ethics and integrity field

6 | Ethics and Integrity

b. To broaden students thinking in differentiation of the different terms. c. To reflect on the different terms.

ETHICS Ethics is defined by different scholars as follows;

Is a set of moral values that justify a standard of behavior of individuals, societies, organizations and professions.

A system of moral principles that deals with values relating to moral conduct, with respect to the rightness and wrongness of certain actions and to the goodness and badness of the motives and ends of such actions. It involves systematizing, defending, and recommending concepts of right and wrong behaviouri.

A set of accepted norms and standards of conduct that establish guiding principles of public and private conduct of those who serve the public. Worth noting is that different societies, professions or institutions may have their own unique values or ethics.

Ethics focuses on the right or wrong behaviour well based standards of wrong and right that prescribe what humans ought to do, usually in terms of rights, obligations, fairness, benefit to society.

Types of Ethics

Individual Ethics

It is a collection of individual ethical values that guides oneself to distinguish between right and wrong, good and bad, should and should not be done, can and cannot be done. The choice between these things always happens on the job, in their daily lives, or when interacting with others.

Organizational Ethics

For those who work within an organization, organizational ethics is a guideline for him on the job, such as the need to hold on to the clean, efficient, trustworthy, honest, truthful, transparent, accountable and fair values. Since the organization deals with the public, ethical organizations also demand that the officials should comply with the Client Charter.

Professional EthicsProfessional ethics encompasses the personal and corporate standards of behaviour of professionals. Due to the personal and confidential nature of many professional services, and thus the necessity to place a great deal of trust in them, most professionals are subject to strict codes of conduct enshrining rigorous ethical and moral obligation.


Professionals are capable of making judgement, applying their skills and reaching informed decisions because they have received relevant training. Professional ethics are also known as Ethical Business Practises Among the professions are medical, judicial, legal, accounting, journalism and teaching. For example, a doctor or a judge is bound by the ethics of its occupation. An editor, author or journalist will have to abide by journalism ethics in information dissemination through the media. Similarly, a teacher must also abide by the teaching ethics.

INTEGRITYIs a positive set of attitudes which foster honest and ethical behaviour in work practices. It is a virtue of practicing what you preach. It is also being truthful, honest, open and obedient to strong moral principles and values.

In simpler terms, integrity is acting with respect for self and others. Even though integrity can be influenced by upbringing and exposure, it cannot be forced by outside sources. It is a choice not an obligation. When we are acting with integrity we do what is right even when no one is watching.

Integrity is more than simply the absence of corruption. Rather it involves adopting and maintaining a positive set of attitudes and values which give effects to the organization’s aims, objectives and the spirits of its integrity strategy. Integrity is consistency between values and actions. A clearing agent with integrity does what he/she says will do. It also knows when to choose two courses of action in a certain way.

Integrity is defined as “adherence to moral and ethical principles acceptable as being good in a given community”. For many organisations, these principles are usually spelt out on policy documents, strategic statement, Mission and Vision Statements, Core Values and Codes of Conduct/Staff Regulations. To put it in its proper perspective, integrity is based on the ethics and noble values and their concrete manifestations in daily lives of individuals, organizations and public offices. It is strict adherence to a moral code, reflected in transparent honesty and complete harmony in what one thinks, says and does (internet)

Integrity in general is a superior quality that exists as a whole and cohesive on the individuals and organizations. It is closely associated with the ethical integrity. It is based on ethics and ethical reflection in daily actions

Integrity may be categorized as:

Individual integrity


Is the harmony between what an individual says and does. His or Her actions are in accordance with moral and ethical principles as well as laws, policies and regulations and do not go against public interest. It also reflects the promptness, correctness and the quality of the actions. Individual integrity is a consistency between the individual and his promise; consistency between actions and the morality, ethics and law; and consistency between self-interest with public interest. The individual’s action is also fast, accurate and quality. When he acted consistently in many ways, he is said to have integrity. When doing the opposite, he is claimed to have poor integrity.

Organizational Integrity Is reflected in the formulation of its Code of ethics, client’s charter, and systems or work procedures, as well as compliance with the best practices. If these are constantly and strongly upheld, they become the culture of the organization.In addition to individual integrity, organizations must also have integrity. Integrity of the organization is reflected in the formulation and implementation of codes of ethics, client charter or systems and work processes and adherence to best practices. Organization’s ethical codes are emphasized, repeated and internalized by members of the organization to become more common and eventually become the organizational culture

Public Servant Integrity

For individuals who are entrusted as those in public services, integrity implies that they are obliged to implement the power entrusted in line with public interest. Public service officers shall not be abusing his power for his personal, family, relatives or kin. When there is conflict of interest, it must be resolved by giving priority to the public interest. Thus, the officers should be transparent and sincere, must bear the responsibility to the leader, subordinate and other parties

Integrity is the single most important attribute someone can have and the most difficult to preserve.

CORRUPTION.In philosophical, theological or moral discussions, corruption is Spiritual or Moral impurity or deviation from an ideal. In business/economy, corruption is payment for services or material which the recipient is not due, under law. This may also be called bribery, kickback.

Corruption is defined as the use of Public position/office for personal gain, use of official position, rank, or status by an office bearer for his own personal benefit.


Withholding information on fraud perpetrated by customs agents

Examples of Corrupt behaviour can include;a. Briberyb. Extortionc. Fraud d. Embezzlement


e. Nepotism f. Influence Peddling, etc

Common Wealth Secretariat 2000 defined it as the abuse of public office for private gain. This definition has been encaged because of the widened scope of corruption to cover the abuse of all offices of trust for private gain, whether in the public or private sectors.

MORALITYStanford Encyclopaedia of Philosophy defines morality as conformity to the rules of right conduct or virtuous conduct.

Morality can also be the quality of being Moral or a system of moral principles entrenched in an institution. It is the human conduct of doing what is right and fitting.

Examples of Moral Behaviour in C&F Examples of Immoral Behaviour C&F

The use of client’s money for the right purpose

Communicating the truth of the transactions to the clients

Submission of right and genuine documents regarding transactions done e.g. port charges,

Cheating on the client to pay more than what is required of the service.

Giving false information about the transactions to the client.

Submission of forged documents by the agents

Deliberately break seals, steal own goods and fake a Robbery


Use of abusive language by customs agents to their clients


FRAUDFraud can be defined as:

a. Fraud is an intentional deception made for personal gain or to damage another individual. Defrauding people or entities of money or valuables is the most common purpose of fraud.

Forging Commercial Invoices.

b. Fraud is also the act of deliberately deceiving another individual or group in order to secure an unfair or unlawful personal gain at the expense of that party. Fraud can be a civil and or a criminal offense. Civil action can be brought against a person who has committed fraud in order to seek compensation for the damages caused by the fraud.

c. Fraud is also taken to be intentional perversion of the truth in order to induce another to part with something of value or to surrender a legal right. Fraudulent People are people who are not what they pretend to be. They are Fraud stars/ imposters.


Consequences of Fraud

1. Forfeiture of goods


2. High penalties that are costly to the business.3. Loss of business.4. Excess tax and Penalties5. Loss of reputation6. Torment to self and family7. Poor role models to our future generation


TOPIC 2: ETHICS AND INTEGRITY FROM A GLOBAL PERSPECTIVE

2 HOURS

SESSION OBJECTIVES a. The trainee will be able to explain the concepts of integrity from a global

perspective.b. They will understand the different conventions and protocols relating to corruption.c. They will be able to understand corruption in the national context.

INTRODUCTION

The ethical issues in business have become more complicated because of the global and diversified nature of many large corporations and because of the complexity of economic and social , political and government regulations, hence the C& F field must decide whether to adhere to constant ethical principles or to adjust to domestic standards and culture.

THE WORLD CUSTOMS ORGANIZATION (WCO) REVISED ARUSHA DECLARATION ON ETHICS.

BACKGROUND TO THE WCO’S STANCE ON INTEGRITY

For over a decade, the WCO has played an active role in addressing the complex problem of corruption in Customs administrations. From the late 1980s onwards, when it was still a taboo to openly discuss the problem of corruption in international forum, the WCO recognized and acknowledged that corruption could be a major threat to the efficiency and effectiveness of customs services.

The WCO thus set about developing a comprehensive strategy and consistent programme to promote integrity in Customs. Since then, the WCO’s integrity strategy and programme has moved towards in logical phases.

REVISED ARUSHA DECLARATION AND INTEGRITY DEVELOPMENT GUIDEPhase 1:In the current phase, the WCO’s work in the integrity domain is characterized by the bringing together, integration and promotion of its instruments and initiatives. The WCO thus adopted the Revised Arusha Declaration at the 2003 Council Session to help Members implement it; the WCO produced an Integrity Development Guide as a complete set of integrity tools, incorporating existing assistance instruments. The WCO Integrity Action Plan was also updated for 2005/2006


Phase 2:Mechanism, instruments and action planPhase 2 saw the creation of an institutional mechanism through the establishment of an Integrity Working Group, now known as the Integrity sub-Committee and assistance instruments (WCO Integrity Self-Assessment Guide and Model Code of Ethics and Conduct) as well as the WCO Integrity Action Plan.

Current phase Basis of the current strategies: The strategies are based on the following main assumptions. Corruption is most likely to occur where Customs Officials:

Enjoy monopoly power over clients; Have discretionary power over the provision of goods or services; The level of control or accountability is low.

A number of additional factors also need to be considered as contributing to the probability of administrative corruption. These include:

The relative level of remuneration available to customs officials; The degree to which the organizational culture and behavioral norms foster or

actively discourage corruption behaviour; The deterrence value of the administrative controls in place; The level of face to face contact between Customs Officials and clients.

For any deterrence to be effective, it must present a high risk to violators. The fear of being caught must be greater than the incentives associated with corruption. The WCO’s approach in terms of its integrity policy is very clear: each Member country can take advantage of a number of instruments, mechanisms and suggestions developed by the WCO for establishing an action plan. These tools should enable Members to carry out self assessment in the integrity domain, and consequently adapt their resources for combating corruption and developing integrity to meet the actual situation in their customs administrations.The WCO can make proposals, but under no circumstances should these actions be considered obligatory by its “members”.

Refer to ANNEX 1 for the detailed revised Arusha Declaration and integrity development guide


KEY INTEGRITY DATES:

1993The WCO’s commitment to integrity begun in 1993 with the Arusha Declaration, and continues in 2005 with Global Forum IV on Safeguarding Integrity in Brasilia.

1994The WCO has developed different instrument to help its Members implement an integrity programme. In this section you will discover the four (4) main tools to assist you to that end.

The four tools are the Revised Arusha Declaration, the Integrity Development Guide, the Model Code of Ethics and Conduct, and the Compendium of Integrity Best Practices. Now you have familiarized yourself with the WCO tools, it is important that you fully understand the benefits that can be gained from their use.

Explaining the need for Integrity PolicyThe nature of corruption and development in the field of integrity are constantly changing. In particular, as more Members undertake integrity self-assessment and evaluation, there is a growing body of knowledge and experience that Members can draw in the further development of their integrity strategies.

It is important therefore that integrity strategies are flexible and are designated to be part of an ongoing process of continuous improvement and reform. Ideally, integrity strategies should be developed as part of a Customs administration’s overall governance and planning processes. That ensures that integrity strategies form part of the overall strategic direction of the administration

The benefits of the WCO tools in an integrity policy.The WCO’s tools provide you with a working basis for implementing the measures to promote and maintain integrity. They are a basis which can be adapted to the specific requirements of your administration, and this is what makes these tools very powerful.They will lend credibility to your decisions and ensure that your efforts are acknowledged by other administrations.


OTHER CONVENTIONS AND PROTOCOLS ON CORRUPTION There are also other international agreements on preventing and combating corruption generally. These include:

AU Convention on Preventing and Combating Corruption - 2003 UN Convention Against Corruption - 2003 OECD Convention on Combating Bribery of Foreign Public Officials in

International Business Transactions – 1997. (Source: 2006 John Hatchard, Crown Agents)

The AU Convention (as well as the UN Convention & other regional anti-corruption instruments) contains four “pillars” for tackling corruption:

• Prevention; • Criminalization; • Cooperation between states in investigating and prosecuting corruption and • Recovery of the proceeds of corruption.

ETHICS AND INTEGRITY IN THE NATIONAL CONTEXTTo address ethics and integrity, there is need to place the notions within the cultural contexts of societies in national states. This involves setting up a framework, requiring elaborate definitions of the following;

a. Culture; Culture is a system of values and norms shared amongst a group of people that when taken together constitute a design for living. Values are abstract ideas forming the keystone/ backbone of a culture and pertain to what is right, good and desirable and make up a set of premises on how things ought to be. Such abstract ideas include:

• Justice• truth • honesty• loyalty• Social• Collective responsibility.

Norms are social rules and guidelines that prescribe the appropriate social behavior. The violation of these usually has serious consequences of retribution.

b. Society


Society is a group of people sharing a common set of values and norms. It is constituted by a particular culture based on its own set of well defined values and norms.

c. Nation State The nation state is a political creation and construction and may be constituted by one or more societies or cultural groups with minor and major variations in the values and norms that define each of them. e.g the C&F Fraternity

Ethics and Integrity in the national perspective, falls into the notion of corporate social responsibility and of that of the social responsibility of the individual profession exercising his activities within an organization or outside it as an independent self employed person.


TOPIC 3: CORRUPTION2 HOURS

SESSION OBJECTIVESTrainees should be able to:

a. Identify causes and forms of corruptionb. Identify the forms of Corruption within the C&F sectorc. Outline the consequences of corruption in the C&F sectord. Identify strategies for corruption prevention within the C&F industrye. Explain the benefits of upholding integrity in the C&F sector

INTRODUCTION There is a growing worldwide concern over corruption at the present time. Lack of transparency, accountability and consistency as well as institutional weakness such as in the legislative and judicial systems; provide fertile ground for growth of corrupt activities.

CAUSES AND TYPES OF CORRUPTION

CAUSES OF CORRUPTION:

Tempting tax officials with bribe


In the Asian Pacific Development Journal Vol 7, the causes of corruption in developing countries are enumerated as follows;

The need for Quick Gains. The urge to have and gain materials so fast by the current generation is very high due to the increasing social needs that create competition among the youths. This differentiates between need driven (satisfying basic requirements for survival) corruption and greed driven (satisfying desires for status and comfort) corruption

Corruption is often attributed to the low salaries. It may be true that it is more difficult to stay honest, hard-working and trustworthy on a low salary, but it is also true that most people with low salaries are still able to do so and that many corrupt officials are people in high, responsible positions, earning good salaries. This notwithstanding, low salaries are not a valid reason for and do not justify corruption.

Complex and bureaucratic procedures A large number of laws, rules, regulations, and administrative orders restricting business and economic activities thereby creating huge opportunities for corruption especially if the restrictive measures are applied in a selective, secretive, inconsistent and non-transparent wayWeak Institutional /Judicial systems / impunities. There are no effective mechanisms and institutional arrangements in the country to hold administrators accountable for their actions.

Culture and the deteriorating morals in the generation. The environment plays an important role in shaping individual values and behaviour. One important component of the environment is culture which is shaped by both history and contemporary developments. A culture that places a high value on integrity will help create the kind of environment conducive to the development of upright individual character. A culture that does not stress integrity will influence individuals to be laid back, irresponsible and to develop the habit of shirking their responsibility or passing the buck to others.

Incompetence. Where service providers lack in the particular competencies necessary to enable then discharge their duties effectively, they are likely to use other avenues to get things done including bribery and other forms of corruptions.

Lack of professionalism. Professionalism presupposes special skills required of a group of people involved in a particular trade. This brings a strong sense of ‘professional pride’ and often emphasizes professional ethic.


Unhealthy competition Companies competing to capture and keep the market often deploy strategies that cannot pass integrity test so as to please the client.

Examples of Corrupt behaviour can include;a. Briberyb. Extortionc. Fraud


TYPES OF CORRUPTION:

Adopted from Vogewede &Associates Corruption Control.com


Competence

Cheating IneptitudeResistanceTheft

Authority

Privilege Abuse Contract Embezzlement Harassment

Favoritism

Supply chain Nepotism PrejudiceDiscrimination

Tribute

Commission Tapping Bribes ExtortionProtection

CORRUPTION

CORRUPTION WITHIN THE CLEARING AND FORWARDING SECTOR

Delays and insufficient services are considered to be the major constraints in conducting business, with issues of delay and high taxation considered to provide the greatest opportunity for bribery in the C in the C&F Industry.

The processes entailing declaration and valuation under customs procedures are the most prone to corruption under customs procedures.

Corruption may take forms of bribery to obtain licenses and bribery of customs agents in a bid to compromise their position of the taxes. A survey done by USAID on corruption at transit points indicated that the amount payable as bribes is largely based on consignment value.

A bigger sum of money of the bribes are paid before the deal is closed. The public official, when asking for bribes tend to mostly operate in solitary and most often the not, clients are aware of the bribes or intention for the bribe because the agents inform the client

CONSEQUENCES OF CORRUPTIONAt national economy levelAt the level of the national economy, corruption has the following effects:

i) Allegations and charges of corruption lead to fall of government and Lead to loss or withdrawal of international aid

ii) An obstacle in the process of economic development. Corruption has a serious adverse impact on infrastructural growth of developing countries

iii) Poor economic performance.iv) Revenue loss and reduced resources available for public servicev) Disregard of standards and the Pillars of integrityvi) Social unrest, lawlessness.vii) Restricted growth of business.viii) Increased costs of goods and services.ix) Reduced direct investment by private sector interests.x) Barrier to international trade and investment.

At the organizational levelAt the level of the organization, corruption has the following effects:i) Ruin of organisational and business firms reputation ii) Loss of trust for the organization.iii) Loss of business


iv) Low productivity, reduced or stagnated growthv) Looting of organizational resources.vi) Underperformance in the core business

At the individual levelAt the level of the individual, corruption has the following effects:

i) Ruin of personal careers. The mass media feeds on scandals and improper conduct because such is extremely newsworthy and would lead to massive sales at the expense of an individual’s repute.

ii) Loss of confidence in the ability of the public service to provide adequate services.

iii) Increased insecurity in the community.iv) Low purchasing power, low pay etc.v) Having to pay higher or exorbitant prices for goods and services.vi) General moral decay in the society due to the erosion of values and standards.

STRATEGIES FOR PREVENTING CORRUPTION WITHIN THE C&F INDUSTRY

a.Broad based capacity building to strengthen all pillars of integrity. There needs to be leadership that is confident in introducing accountability and transparency and focus on objectives and results working towards the WHAT and through the WHO as shown below;

WHAT WHO


Skills

Information

Incentives

Integrity

Leadership

Mindset

Tools

Private Sector

Media

Watchdog Agencies

Judiciary

Civil Society

Parliament & Executives

Enforcement Agencies

Capacity Building

b. Raising Public awareness through: Public Education and awareness campaigns Conducting annual broad based national integrity workshops where

stakeholders are invited to discuss problems and propose solutions Integrity surveys Inform citizens about their rights and empower them to monitor the Clearing

and Forwarding

c. Imposition of heavy penalties for corrupt officials d. Improving on policies and procedures and legislative reforms.

e. Regular Anti Corruption meetings integrated meetings that bring together Police, Immigrations, and Customs.

BENEFITS OF UPHOLDING INTEGRITYQuote: ‘’The highest courage is to dare to be yourself in the face of adversity. Choosing right over wrong, ethics over convenience and truth over popularity......these are the choices that measure your life.”

Benefits can be both to the individual and the organisation:

BENEFITS TO THE ORGANISATION:a. External and internal organisation perception, High performance and increased

credibility for the organisation that will lead to increased customers, clients and employees loyalty commitment.

b. Advantage over competitors, Ethical companies will have strong business networks and collaborations with investors hence bigger company opportunities for diversification and growth over unethical counterparts.

c. Builds trust and confidence for an organisation and hence customer retention that will lead to increased profitability and sustainability.

BENEFITS TO THE INDIVIDUAL:a. Job security, whereby an individual will fear restricting, sell off and appraisals.b. Career Success which includes recommendations, promotions, and better

remunerations leading to assured better standard of living. c. Integrity builds trust and confidence, Authority does not come from titles, positions

or policies but from trust and confidence from people.d. Integrity has high value of influence; People’s minds are changed through

observation not arguments.27 | Ethics and Integrity

e. Integrity facilitates high standards, because integrity has high influence value, it gives the leaders a unique opportunity to set high standards.

f. Integrity builds character not reputation, Reputation is what people think we are but character is who we really are. Character is built by a lifestyle of integrity.

g. Sense of completeness: When you follow your own moral compass and do what you think is right, you achieve a sense of completeness. If you disobey your own value system, you become dividend, unbalanced and uneasy.

h. Builds social relationships.


TOPIC 4: FRAUD 1 HOUR

SESSION OBJECTIVESTrainees should be able to:

a. Identify the different types of fraud most frequently experienced in the C&F industry.b. Explain the concept of tax evasion.c. Explain the consequences of tax fraud and tax evasion.

TYPES OF FRAUDa. Impersonation or Perpetuation to be one of the government officials.

A scheme where customers are required to pay taxes, bribes to purported government officials, legal fees with the promise that all expenses will be reimbursed as soon as the deal goes through.

b. Business Trading Frauds (False licensed Clearing and Forwarding company)The company purports to be in legal operation and yet it is not authorised to undertake the profession. Some also open for a short period only to defraud the clients.

c. Abuse of position of trust This is when someone abuses their position of authority or trust against another person for personal or financial gain, or to cause loss to another. A person of trust or authority could be a friend, family member or a company employee. The personal gain is often financial or causing loss to another person and can happen to an individual or business

d. Advance fee fraudThis is where fraudsters (who may be the clearing agents/company) target their customers/clients to make advance or upfront payment or goods/services or financial gains that do not materialise

e. Computer Hacking

This involves breaking into computers and computer networks so as to remove information or evidence attributing to payment of specific taxes and thus commit fraud.

TAX EVASION


This is a type of tax fraud where a person deliberately gives incorrect or misleading information in order to pay less or no tax. Tax fraud occurs when individuals working and earning income knowingly and intentionally fail to file the income tax returns or falsifying information on a tax return.

Persuade tax administrators/tax payers to evade taxes through many ways such as; Misclassification. Under declaration Misdeclaration

Examples of such include; Failing to state the correct amount on declarations made Over stating deductions and exemptions Falsifying tax documents. Concealing or transferring income and reporting personal expenses on imported

items.

CONSEQUENCES OF FRAUD AND TAX EVASION

The consequences for fraud will depend on the nature, scope, and severity of the offense, whether the fraud was committed by an individual or group, and the state or government laws that apply to the case.


a. Civil Suit Civil action can be brought against a person who has committed fraud in order to seek compensation for the damages caused by the fraud.

b. Punitive fines, probation, and other penalties.These arise out of the civil suits as compensation for the offence alleged by the complainant.

c. Loss of reputation

d. Incarceration (Jail)Sentencing can range from scenarios where a person does not go to jail, or the way up to sentences that are extremely lengthy in complex frauds


TOPIC 5: ETHICAL BEHAVIOR

2 HOURS

SESSION OBJECTIVES

Trainees should be able to:

a. Explain the fundamentals of work ethics b. Explain the principles of Ethical power c. Explain the benefits of creating a C&F Ethical Environment d. Demonstrate understanding of the application of the FEAFFA Code of Ethics in the day to day C&F work.e. Demonstrate how to handle ethical dilemmas

INTRODUCTION

Ethical behaviour in an organization is manifested in the following:• Automatic honesty, e.g. when making financial claims• Exemplary punctuality and commitment to work • Readiness to declare conflicts of interest• Readiness to follow and enforce laid down procedures• Moral uprightness• Selflessness, objectivity ,impartiality and diligence• Accountability and responsibility• Willingness to declare assets• Enthusiastic adherence to Codes of Conduct• Transparency/openness• Refusal to participate in any form of corruption irregularity or indecency• Readiness to act on or report instances of corruption• Respect for authority and for all individuals• Responsiveness• Commitment to promises and appointments

A person with good ethics ought to:• Understand company’s policies, codes, procedures, rules, values and follow them.• Play your role properly and professionally and be ready to take responsibility for

your actions, omissions, commissions etc.• Support others and the organization to act ethically• Obey the law


FUNDAMENTALS OF WORK ETHICS

a. Code of ConductA key element of any effective integrity program is the development, issue and acceptance of a comprehensive code of conduct, which sets out in very practical and unambiguous terms the behaviour. Penalties for non-compliance should be articulated in the code, calibrated to correspond to the seriousness of the violation and supported by appropriate administrative and legislative provisions. Cases of corruption, which have been detected and dealt with, should be well, publicised to ensure firms and staffs are aware of the commitment of the associations/organisation to deal with integrity issues.

A Code of Conduct describes the standards of behaviour and conduct required of companies/employees to ensure that the integrity and good reputation of the clearing and forwarding industry.

An effective code of conduct must: Describe in very practical and clear terms the standards of behaviour expected of

all; Provide a guide to solving ethical issues. Provide a effective dispute resolution system

The Code should be regularly reinforced to companies and staff. Management must lead by example and in order to earn the moral authority to sanction those who fall short of the standards.

The penalty system associated with breaches of the Code must be sufficient to provide a real disincentive to engaging in corrupt behaviour. Penalties should be to correspond to the seriousness of the violation and can include:

• restitution,• fines, • demotion, • suspension and dismissal for serious offences, • Less obvious penalties such as peer pressure, restrictions, transfers,

reduction in autonomy or discretionary power, loss in professional status.• Negative publicity.

At the company level, appropriate conditions of employment, remuneration, and administrative and legislative provisions must support the practical implementation of the Code and be sufficient to provide a positive incentive.


b. Individual standards and values This involves an evaluation of self to derive the sources of ethical norm. The figure below illustrates the different sources / factors of an Individual’s ethical behaviour.

NB: Important Ethical Questionsa. What is?b. What ought to be?c. How do we get from what is to what ought to be?d. What is our motivation for acting ethically?

c. Managers and co-workers’ influence Managers must demonstrate integrity based upon deeply felt ethical principles in business situations. Managers have authority and may influence employees’ actions and therefore should create a work environment that fosters ethical and responsible behaviours.

PRINCIPLES OF ETHICAL POWER.There are five principles of Ethical power as adopted from The Power of Ethical Management by Kenneth Blanchard and Norman Vincent Peale:


The Individual Conscience

Friends

Society at large

Employer

Religious Beliefs

Local Community Religions of the

Country

Profession

The Law

Family

Fellow Workers

1. Purpose: The mission of the organisation must be communicated from the top. The organisation should be guided by values, hopes and a vision that helps to determine what is acceptable and unacceptable behaviour

2. Pride: People should feel proud of themselves and their organisations, knowing that when they feel that way, they can resist temptations to behave un ethically

3. Patience: People should believe that holding to their ethical values will lead them to success in the long run. This involves maintaining a balance between obtaining results and caring how they achieve these results.

4. Persistence: People need to have commitment to live by the ethical principles. There auctions need to be aligned to the Purpose.

5. Perspective: Managers and employees in a company should take time to pause and reflect, take stock of where they are, evaluate where they are going and determine how they are going there.

CREATING A C&F ETHICAL ENVIRONMENTIn today’s first paced, competitive and demanding business environment, employees in both small and large businesses can find themselves facing difficult ethical dilemmas. For this reason, the C& F industry needs to provide knowledge and resources to help employees act ethically. There are several critical ways to develop and create and sustain an ethical work environment as indicated below:Exemplary leadership; Company management sets the tone by committing to integrity and encouraging ethical behaviour from employees;

Having a comprehensive Code of conduct. Every Clearing and Forwarding firm should have a code of conduct/code of ethics that addresses a wide range of topics to include the following:

Abuse of Office Relationship with clients Confidentiality Corporate practices around diversity Harassment


The use of corporate property Fair treatment of staff Drug and Alcohol Abuse

Conducting Effective Ethics training. This creates awareness, addresses employee questions and concerns and reinforces the company’s requirement for ethical behaviour

Having a Strategic Communication Plan. Each C&F Company should design a communication plan that will consistently reinforce ethical behaviour that will remind employees about resources available to them and how to access them.

Instituting an Ethics hotline. |Employees can call to ask questions about ethical dilemmas they face or report any suspected Unethical behaviour. The processes should ensure confidentiality and anonymity.

FEAFFA CODE OF ETHICS The code of ethics is a regulatory standard for professional ethics. It is very important because it gives us boundaries that we have to stay within, in our professional careers. Federation of East African Freight Forwarders Associations (FEAFFA) has developed a model Code of Conduct to prevent exploitation of the client and preserve integrity of the profession. This is not only for the benefit o the client but also of those belonging to the profession. Each national association affiliating to the federation is required to enforce the Code to its membership. The Code should also serve as a guide to companies in establishing their own codes of conducts.The FEAFFA Code of Ethics embeds in itself a Disciplinary code that allows the profession to define a standard of conduct and ensure that individual C&F practitioners meet this standard. This thus maintains the public’s trust in the profession, encouraging the public to continue seeking their service.

The Code of Conduct has the following objectives: To uphold a high standard of business ethics and professional conduct among

Clearing and Forwarding Agents (CFAs) and all other professionals within the freight logistics industry across Eastern Africa;


To ensure a high level of professional education and experience essential to provision of efficient services;

To encourage operation of financially sound, stable and accountable Clearing and Forwarding Agents;

To combat corruption, freight logistics fraud, illicit trade and trafficking of goods and persons, including unsafe or controlled substances; and

To provide a framework through which national associations can monitor and enforce integrity and professionalism in their various jurisdictions.

To promote healthy competition among operators in the industry. Provide the basis for regulating behaviour and framework for dealing with errant

operators and resolution of disputes. To Protect and promote the reputation and good public image of the clearing and

forwarding industry.

The broad areas covered by this Code include:Article 3. Professional qualifications .i.e. the basics for qualifying as a

professionalArticle 4. Financial standing required of a qualified Clearing and Forwarding

AgentArticle 5: Code of Professional Conduct (the dos and don’ts)Article 6: Procedures for handling complaints and enforcing disciplineArticle 7: EnforcementArticle 8: Disciplinary actionsArticle 9: Harmonisation and compliance

Visit www.feaffa.com for the code of conduct.


http://www.feaffa.com/

CORRUPTION RISK ASSESSMENT AND MANAGEMENT

Corruption Risk is any behaviour that is illegal, immoral or dishonest, by people in the organisation such as bribery, extortion, nepotism, embezzlement, misuse of power Corruption Risk Management is a process that helps identify potential corruption risks in an organisation, assess those identified risks in terms of severity to the organisational performance, goal and image, analyse its causes and ultimately help in bringing about corrective measures to minimise or eradicate those risks. It is also about identifying the corruption risks and preventing them. These risks if not managed appropriately can lead to number of complications and destruction of the organisation itself. Corruption risks can exist at all levels starting from decision making bodies to the operational and tactical levels, hence need for prompt awareness and mitigation.

IMPORTANCE OF RISK ASSESSMENT TO THE MANAGEMENTRisk management involves coming-up with policies and procedures to seal off the corruption loopholes in order to prevent or eliminate corruption. Risk assessment is important in that:

a. It helps the management to identify areas in the organization where corruption may occur;

b. It helps management to ascertain the degree or likelihood of corruption happening.c. It enables management to know the likely consequences of corruption when it

occurs in the organization such as financial risks, public embarrassment and waste of time and resources in dealing with corruption.


STEPS FOR CORRUPTION RISK ASSESSMENT

Step One: Risk Identification

Risk Identification entails;I. Breaking the issue into components

II. Detecting the risks III. Finding the core risks in the structural, institutional and societal view (For example;

Misuse of authority, lack of transparency in execution or bribery and Nepotism respectively)

Step Two: Risk Assessment

This involves evaluation of the recognized risks with impact and frequencies and set the standards of the scoring.

The goal is to generate a list of all possible risks in an organization and clearly document what each one involves; it will enable staff to understand exposure and risk factors relevant to the systems, functions and operations in their area of work.

Step Three: Select the major risks by identifying the risks with high scores

Cluster the risks based on the weightings and select the major risk areas.


Risk IdentificationWhat Risks are threats

to us?

Risk Assessment Scoring Risks

Select Major RiskWhat should be

innovated

Cause AnalysisFinding Causes

Strategic SolutionResponse and Strategic

Solution

Choosing & Implementing a course

of actionFeasible Plans

Step Four: Cause Analysis:

Know the causes of the major risks, lead to find a solution of each of these causes that us helpful to manage corruption risk.

Step 5 Strategic Solution Look at the current response level that the organization already has in place for example staff awareness, resource availability and identify a short term and long term solutions

Step 6: Choosing and implementing a course of action.

This involves development of a Corruption Prevention PlanA corruption prevention plan is a set of actions that may be applied to check corruption and resources directed towards sealing loopholes that induce corruption. This has the following benefits:

Better provision of services; Better infrastructure; Improved health and education services; Conducive business environment; Improved security; Increased employment, better remuneration; Reduced poverty; Improved profitability and business expansion; Reduced taxation, better revenue collection; Overall economic improvement, and Higher standards of living;

Sample Corruption Prevention Implementation Template Risks Detailed

PlanResponsibility Centre

Schedule

J F M A M J J

Actors in corruption prevention plana) Management

Formulating anti-corruption policies,Assigning tasks in the anti-corruption,Defining reporting procedures, andDesigning courses of action on reports.

b) Employees40 | Ethics and Integrity

Identifying where corruption opportunities exist,Reporting corrupt practices to top officials,Non-involvement in corrupt practices

c) Corruption prevention committees (CPC’s) composition)Formation of CPCs at various levels of the organisation

HANDLING ETHICAL DILEMMASFACING TOUGH CHOICES - RIGHT VS. RIGHTEthical Dilemmas is a situation that puts one to choose between right and wrong. Rushworth Kidder, in his book "How Good People Make Tough Choices," describes many choices that are more difficult than the typical right vs. wrong decisions that we make. When we are faced with a clear-cut "wrong" this is not really a dilemma. Upon sober reflection, most of us can differentiate between right and wrong and thus there is no real moral struggle. The struggle results from decisions we must make between two "rights."

Some of these dilemmas are:Truth vs. LoyaltyTruth means conformity with facts or reality; loyalty means allegiance to a person, group, government or set of ideas. An example of the dilemma here is, "Would you tell a lie to save a life?"

Individual vs. CommunityThe individual vigorously pursues his or her own self-interest; the community is a place where people know and care for one another. The dilemma is at its core, a clash of values. Do the rights of the individual outweigh the rights of the community or the opposite?

Short Term vs. Long TermThese are everyday dilemmas: Save for retirement or buy a new car you really need? Sacrifice present gains for future rewards. Sacrifice future gain for present needs. Should I invest or consume?

Justice vs. MercyJustice means to follow the law and stick to our principles regardless of the circumstances. We are blind to personalities or situations. Mercy is never blind. Mercy means to look through the lens of compassion in making decisions. We recognize that mercy and justice both have strong claims on us. These claims create powerful and sometimes wrenching dilemmas


Resolution of these dilemmas requires determining which "right" is more right. Three principles for helping to make this decision are:

The Ends-based Principle : what is the greatest good for the greatest number?

The Rules-based Principle : follow the principle you would want all others to follow in similar circumstances.

The Care-based Principle : this is essentially the Golden Rule - Do unto others as you would have done unto you.

These three principles allow you a means to reason your way through a dilemma - to provide the lenses through which to see the problem you are trying to resolve. By applying one or more of these resolution principles, you can more clearly evaluate options and make the best decision.

The following steps can help to analyze and resolve given ethical dilemma:

1. Analyze the consequencesIt is easier to look at the consequences of actions you are considering by considering the range of both positive and negative consequences assuming that one has a variety of options. Questions to ask

Who will be helped with what you do? Who will be hurt? What kind of benefits and harms are we talking about? Are there any long term and short term effects?

2. Analyze the actions This is where one concentrates strictly on their actions and how they measure up against moral principles like honesty, fairness, equality and respect and the organizational core values.

3. Making a decisionAnalyze and weigh both options in step one and two and make a decision since it will guide you on the steps to follow. This is dealing with morals or the principles of morality, pertaining to wrong and right in conduct. It is the act of being in accordance with the rules or standards for the right conduct or practice, especially the standards of a profession.


CONCLUSION:

This document summarizes key, well-thought through considerations, that are deemed significant in enhancing professionalism in the Customs clearing and Forwarding industry. It involves creating an integrity driven Industry that is committed and accountable across the industry practitioners.

This will build a cohesive and harmonious society with sound morals that will consistently enhance the competitiveness and sustainability of professionalism in order to effectively endure the globalisation challenges of the 21st century.

Appreciation, good interpretation and application of ethical principles by the customs agents in their day to day activities will certainly be a powerful force to change the outlook of the industry.

We, the Members of the federation of East Africa Freight Forwarders Association and East African Revenue Authorities call upon all stake holders to implement comprehensive and sustainable integrity action plans to collectively fight corruption.

Integrity is the foundation on which our industry must be built for without it; we do not have the trust or confidence of the public.

.CASE STUDY ONE:

When we were children, our parents told us that it was wrong to tell a lie. Still, we have all told lies at one time or another. If most of us agree that telling lies is wrong, how do we justify continuing to do it? Lying is closely related to interpersonal communication. Often we tell lies as a "necessary" part of social interaction.

With your table team, discuss the following situation:You are a manager in a Clearing and Forwarding firm. A subordinate comes to you and asks about a rumor she has heard that Audit will be moved from its current location to a city 200 kilometers away. You are aware that there is indeed a plan to move the function and all of its employees, but you are not supposed to share this information while the restructuring is pending. Your subordinate employee is very concerned as she has parents living nearby who are not well. The employee is worried about her job vs. her family


ETHICAL DILEMMAS - IS IT WRONG TO TELL A LIE?

commitments. This employee has been hardworking and loyal, and has always supported your management initiatives. Required;

1. Explain the situation in which the manager would position himself when the subordinate confronts him with the issue of the grapevine.

2. From the manager’s position justify his stand.3. Discuss the integrity and ethics issues.4. Discuss how one’s moral compass can be affected by such factors.

CASE STUDY TWO

A Case Study in Ethics and Integrity.

Friends’ Influence

You are a Director of Eagle clearing and forwarding Co. LTD based at Malaba. While attending regional workshop on single widow you are approached during a break by Paul Johnson, the Customs regional manager with whom your paths crossed often because of your nature of work. Both of you always had a very cordial but professional relationship. Occasionally, you would also see each other at a popular executive club. Mr. Johnson greets you warmly, hands you his business card, and begins to reminisce about your good working relationship. He asks about some of your business colleagues who still work with you and makes other small talk. As the workshop is about to reconvene and you excuse yourself to return to your seat, he asks if he could speak with you after the meeting regarding one of his current transactions. You agree to do so, thinking that whatever the


issues, a face-to-face meeting with a senior customs officer might enhance future working relationship.

After the workshop, you and Mr. Johnson remain behind to discuss the issues on the transaction in question. You listen, take notes, and promise to investigate further upon returning to work. You advise him that you will get the right people together to fact-find and resolve the issues that have been causing offenses and audit queries. Pleased with your quick-handling of the matter, you gather your belongings to leave the conference room, when Mr. Johnson stops you, saying, “There is something else I want to talk to you about.” He proceeds to tell you how impressed he is with you and how you would “fit right in” with the senior management team at cutting Edge clearing and forwarding Co. “You know, you could make a lot more money than you are making now. A lifestyle change, actually. Plus, you’ve already got enough experience and external exposure to qualify for an executive Director position.”

You are flattered and say, “Someday, perhaps.” Mr. Johnson suggests you talk more at the hotel bar during “happy hour” and you agree to meet him there. Over drinks, Mr. Johnson tells you that there is definitely a strategic position at Cutting Edge LTD for you, he would only have to say the word to his Board of Directors and you could pretty much “name your salary.” You tell him a job change is not something you are seeking just yet. “Maybe down the road,” you say. By now, you have had several drinks and as you glance at your watch, Mr. Johnson grabs your arm and says quietly, “A job change is not the only way we can help each other out.” He alludes to your past association and confides that his company is trying to increase its business with enormous clientele. They are targeting some upcoming Government constructions and rehabilitations of different infrastructure that will require expertise. He tells you that this is a fiercely competitive business and asks if you are willing to take up the challenge. Then, out of the blue, he offers to help you out of the current offense in his office. He tells you that no one will ever know because he will be discreet.

Required;

1. What would you do? 2. Discuss the integrity and ethics issues. 3. What laws, if any, have been broken? 4. Discuss how one’s moral compass can be affected by such factors5. What steps should the Director of Eagle clearing and forwarding co. take? And

why?

CASE STUDY THREE


KEEPING IT IN THE FAMILY

You are the human resource manager of Extravagant Clearing and Forwarding Company LTD, aregional clearing company that has turnover of over 10,000 employees and subsidiaries in over five countries.Part of your work is to manage the human resource and oversee hiring competitive, qualified and professional personnel for the company. The group chairman of the mother company announces increase in business leading to an imminent increase of staff especially in the declaration department. Mr.Walusanza is one of your Managing directors in the company and to whom you report directly to in your line of work. He asks you to advertise for the positions needed by the company which you do in line with the company policies.The excise is done successfully and you are requested to present the list of shortlisted names to the next upcoming board meeting for approval for the final interviews. You are confident you have done a good job since you had thoroughly gone through their papers and all were qualified. You remembered a case where a staff had come in from another branch as declaration officer and had caused so much loss to the company. He had a lot of misdeclarations that led to paying of heavy fines and penalties. A few important clients were also lost. After investigations you realized the officer did not have relevant training for the job he was doing. You did not therefore want a repeat of the same. Mr Walusanza calls you to his office and demands for the list of shortlisted candidates for his approval before reaching the board. You do as requested and take a note mentally to pick the list the next day from him.The next day while you call for the list, he tells you to back to your work and assures you that he would take the matter from there. You are bewildered by his behaviour but do as you are requested for fear of insubordination.You do not say anything but during tea break the next day you overhear junior staff saying that Mr. Walusanza’s sister- in- law and girl friend had been seen around dropping their papers with an interest in the advertised positions but you treat this as rumours. During the board meeting, the managing director produces the list for approval but with half of the names completely new. You are completely shocked and it dawns on you that he had retained the list because he had personal interests.

Required;

1. Discuss the integrity and ethics issues.

2. Have any laws been broken?

3. What would you do?


REFERENCES

Adrian Gostick & Dawn Telford Todd Gittin, The Integrity Advantage,Gibbs Smith Publisher( ISBN 1-58685-246-9)Asian Pacific Development Journal Vol 7, No 2, “Corruption: Causes, consequences and cures Business Ethics: A philosophical Reader (Newyork) Macmillan Publishing, 1993 FEAFFA code of conduct, 2010.International Business (2005) ,5th Edition, McGraw-Hill/Irwin Norman, Vincent Peale & Kenneth Blanchard, (2011) The Power of Ethical Management.

www.about.com 3rd August 2012

www.freedictionary.com 3rd August 2012

www.info.lawyershop.ca 5th August 2012

www.lawfirms.com 6th August 2012

www.dictionary.com 7th August 2012

http://www.unodc.org 4th August 2012

www.feaffa.com 4th October 2012


http://www.feaffa.com/

http://www.unodc.org/

http://www.dictionary.com/

http://www.lawfirms.com/

http://www.info.lawyershop.ca/

http://www.freedictionary.com/

http://www.about.com/

ANNEX 1 THE WORLD CUSTOMS ORGANISATION (WCO) REVISED ARUSHA DECLARATION

Revised_Arusha_Declaration_EN.pdf


i Value: A set of beliefs that forms the basis of individual attitudes and behaviour. This belief determines the criteria of good conduct or otherwise, the desired or not, positive or negative

eacffpc ethics and integrity training manual

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training curriculum

east africa customs

effective training

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eastern africa customs

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