COMPANY CULTURE AND PROCEDURES

AC.1.a. Signalling a non-corrupt environment

Does the company take a clear stand against corruption? (Principle 10)

ABOUT THIS QUESTION

Promoting anti-corruption plays an essential role in combating corruption. Not only will it signal to the company's business partners and associates that the company runs a non-corrupt business, it also encourages employees to refrain from being involved in corruption and have an open dialogue of the risk of corruption.

 

The company should comply with relevant international standards, conventions and agreeements such as UN Convention against Corruption, The Inter- American Convention Against Corruption, The African Union Convention on Preventing and Combating Corruption, Anti-Corruption Action Plan for Asia and the Pacific, The Council of Europe Conventions on Corruption, The OECD Convention on Combating Bribery of Foreign Public officials in International Business Transactions, etc.

ANSWER THIS QUESTION

First answer the following indicators (step 1) and then the main question (step 2).

Step 1. Answer the following indicators:

The company's CEO, director or president has declared that the company will not engage in corruption at any time or in any form.

The company has a policy rejecting corruption and requiring all directors, managers and workers worldwide to behave ethically and in conformity with the law.

The company anti-corrution policy includes how to handle requests for facilitation payments, giving and receiving gifts, engaging in sponsorships, giving political contributions, and how to conduct responsible lobbying.

The company has defined benchmarks and indicators regarding its anti-corruption initiatives and reports these to the public (e.g. in its annual CSR report)

The company has defined benchmarks and indicators regarding its anti-corruption initiatives and reports these to the public (e.g. in its annual CSR report)

Step 2. Answer the main question:

Does the company take a clear stand against corruption?

 

AC.1.b. Anti-Corruption risk assessment

Does the company assess the risk of corruption when doing business?

ABOUT THIS QUESTION

Risk assessment is the foundation of implementing anti-corruption tools in businesses. This assessment will have a different focus depending on the specific situation and context, and should relate to internal structures of the company. It is important to include this analysis in the overall evaluation of business relationships and opportunities and look for ways to minimize the risks by providing appropriate counter measures. Operating in countries with a high level of corruption the risk assessment should be implemented in all procedures.

 

Please see for example: OECD Risk Awareness Tool for Multinational Enterprises in Weak Governanace Zones.

ANSWER THIS QUESTION

First answer the following indicators (step 1) and then the main question (step 2).

Step 1. Answer the following indicators:

The company evaluates the potential areas of corruption including factors such as type of transaction, countries of operation, industries, and customers or business partners involved.

The company evaluates the risk of corruption when workers, agents, intermediaries or consultants deal with public officials (including workers of state owned companies).

The company evaluates the risk of internal and external conflicts of interest in relation to business partners.

The company has developed an action plan to address the risk of corruption, and has defined responsibilities for each task, as a minimum for high-risk areas.

The company has identified internal functions with the highest risk of corruption within the company and seeks to address these weaknesses.

Step 2. Answer the main question:

Does the company assess the risk of corruption when doing business?
 

AC.1.c. Awareness raising

Does the company ensure that relevant workers are properly trained?

ABOUT THIS QUESTION

Awareness-raising is essential for the long-term success of fighting corruption. Awareness is not established instantly, but created through ongoing dialogue, training and information about corruption, its impact and how to prevent it.

 

The measures taken by the company should be in accordance with national regulatory requirements, international conventions, agreements, the precautionary approach and best practice. Please see for example: ICC guidelines on Whistleblowing; Combating Extortion and Bribery: ICC Rules of Conduct and Recommendations; Buisness Princilples for Countering Bribery. Transparency International; Partnering Against Corruption - Principles for countering Bribery. Partnering Against Corruption Initiative (PACI), World Economic Forum.

ANSWER THIS QUESTION

First answer the following indicators (step 1) and then the main question (step 2).

Step 1. Answer the following indicators:

The company informs all workers about its anti-corruption commitment.

The company provides regular anti-corruption training for all relevant workers within the organisation e.g. procurement and sales staff.

Information on disciplinary procedures for violations of company anti-corruption policies is available to workers.

The company actively seeks worker feedback and dialogue on its anti-corruption initiatives.

The company has and promotes a function by which workers can safely report suspicion of corruption related cases (e.g. hotline or mailbox) and allocates resources to systematically address the issues that are identified.

Step 2. Answer the main question:

Does the company ensure that relevant workers are properly trained?

 

AC.1.d. Anti-corruption procedures

Do the company's internal procedures support its anti-corruption commitment?

ABOUT THIS QUESTION

Implementing anti-corruption standards into the core structure of the company relies heavily on the development of suitable procedures which are resistant to corruption and able to raise internal alarms. These alarms are signals regarding occurrences which should be investigated at a higher level in the organization.

 

See for example: ICC Tools for Self-Regulation; OECD Risk Awareness Tool for Investors in Weak Governance Zones; OECD Guidelines for Multinational Enterprises.

ANSWER THIS QUESTION

First answer the following indicators (step 1) and then the main question (step 2).

Step 1. Answer the following indicators:

The company has assigned different individuals or departments to be responsible for handling contracts, placing orders, receiving goods, processing invoices and making payments.

The company mentions "anti-corruption" and/or "ethical behaviour" in its contracts with business partners.

The company prohibits informal employment and any 'off the books' record-keeping

The company performs internal audits and has checks in place in connection with all anti-corruption commitments.

The company's procurement, financial and internal audit personnel have clear instructions to look for and to identify alarms, report them to management, and follow-up counter measures.

The company requests external auditors to maintain a critical eye and follow all alarms and irregularities.

Any alarm or irregularity reported by external auditors is systematically addressed by management.

The company monitors compliance and continuously identifies strengths and weaknesses in the anti-corruption initiatives to remain effective and up-to-date in addressing changing risks.

Do the company's internal procedures support its anti-corruption commitment?

 

AC.1.e. Agents and other associates

Does the company's anti-corruption initiative cover agents, intermediaries and consultants?

ABOUT THIS QUESTION

Using agents, intermediaries, consultants or other external service providers does not free the company of its responsibility of implementing its anti-corruption initiatives. Following international law and other anti-bribery legislation, the criminal offence of bribery occurs when a financial benefit or other advantage is offered, promised or given to a public official directly or through agents, intermediaries or consultants. Information, training and monitoring of agents, intermediaries or consultants' activities should be carried out on a continuous basis with a clear line of responsibility within the company.

The measures taken by the company should be in accordance with national regulatory requirements, international conventions, agreements, the precautionary approach and best practice. See for example: Convention on combating bribery of foreign public officials in international business transactions. OECD; Combating Extortion and Bribery: ICC Rules of Conduct and Recommendations; Business Principles for Countering Bribery. Transparency International; Partnering Against Corruption - Principles for countering Bribery. Partnering Against Corruption Initiative (PACI), World Economic Forum.

ANSWER THIS QUESTION

First answer the following indicators (step 1) and then the main question (step 2).

Step 1. Answer the following indicators:

The company conducts an inquiry and/or attentiveness (e.g. financial, legal, labour, tax, IT, environment, market/commercial) on all agents, intermediaries and consultants.

All agreements with agents, intermediaries and consultants are fully documented in written, signed contracts.

The selection and terms of reference of agents, intermediaries or consultants are approved at the senior management level or at a level above that of the management involved in the operations for which the intermediary is hired.

Contracts with agents, intermediaries and consultants include a section on anti-corruption and that the contract-holder must comply with all applicable laws and regulations.

Agents, intermediaries and consultants are provided with information on the company's anti-corruption commitment, anti-corruption policies, training material on anti-corrupt behaviour and information on disciplinary procedures for violations of company anti-corruption policies.

The company ensures that payment to agents, intermediaries and consultants are in line with standard payments for other service providers of similar ranking.

The company only makes payments by bank transfer or check - never in cash - in the country of the agent, intermediary and consultant and never to a third party without prior examination.

Does the company's anti-corruption initiative cover agents, intermediaries and consultants?

 
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