trac: transprency in reporting of social responsibility and an anti-corruption compliance culture 26...
TRANSCRIPT
TRAC: TRANSPRENCY IN REPORTING OF
TRAC: TRANSPRENCY IN REPORTING OF
Social responsibility and an Anti-Corruption Compliance Culture
26th September 2013
David CoatesSenior Advisor
Transparency International UK
At home with Ethics and Compliance
Ethical, Legal and Socially Responsible
Transparency International
• Specialist Anti-Corruption NGO• Founded in 1993• TI National Chapters in over 100 countries
Proetica
Transparency International’s approach
•Bribery of any kind embeds corruption in the system•Corruption has victims•Fighting corruption often requires collective action to achieve systemic change•Zero tolerance
Common Excuses For Paying Bribes
6
IGNORANCE “If only we'd known that it would
be regarded as a bribe…”
COMPLACENCY “We’ve always done it…”
SIEGE MENTALITY “We can only compete if…”
PRETENDING IT’S NOT A BRIBE “It was only a helicopter trip and
a five-course banquet for him and his partner…”
OUTSOURCING BRIBERY “We had no idea our agent
was paying…”
CITING CUSTOM “That’s the way things work here -
it’s different…”
INADEQUACY “We thought our anti-bribery systems
were up to the job…”
Likelihood of companies to bribe abroad by sector
8
7
6
5…
0 = Always
8
Where does Corruption Take Place?
• Corruption can also exist between private-sector parties, their proxies or agents
• Grey area between public and private sectors makes public/private distinction increasingly obsolete
UK Bribery Act
• Section 7 - Failure by a commercial organisation to prevent a bribe being paid for or on its behalf.– Critical Motivator for Social Responsibility– MoJ Guidelines 6 principles ‘Adequate Procedures’– Bad Apple Mitigation
9
Adequate Procedures
– High-level commitment– Risk assessment– Policies and Procedures– Implementation (e.g. training, communication)– Due diligence assessment of partners, agents and contractors– Monitoring and evaluation
10
Need to Merge
