Compliance professionals: What should they monitor in anticorruption?

I recently wrote about the arrival of a new tribe: the compliance professionals, and indicated the areas where their services are needed in organizations. Today, let me focus on specific tasks which are in line with the control processes the Integrity Initiative has developed over time. What are those tasks that he or she has to monitor?

■ No bribes are offered, promised or given to a public official, political candidate, party or party official, or any private-sector employee (including a person who directs or works for a private-sector enterprise in any capacity;

■ No charitable contributions and sponsorships are used as an undue advantage;

■ No facilitation payments are made, as they are prohibited under the antibribery laws of most countries;

■ No gifts, hospitality or expenses are offered whenever such arrangements could improperly affect the outcome of a procurement or other business transactions;

■ No agents, advisers or other intermediaries are appointed without due diligence review;

■  No contractors, subcontractors and suppliers are chosen without proper evaluation and performance audit.

At the same time, the compliance professionals should see to it that:

■ Managers, employees and agents receive specific training on Integrity principles, tailored to relevant needs and circumstances;

■ Processes are designed in the organization that encourage employees and others to raise concerns and report suspicious circumstances in confidence and without risk of reprisal;

■ Effective mechanisms for internal communication are made known to everybody in the organization;

■ The organization maintains accurate books and records and that the right taxes are paid.

As we in the Integrity Initiative are committed to convince 6,000 additional companies/organizations in the Philippines to sign up for clean and ethical business, allow me to highlight the “Process Flow for Signatories” of the Integrity Pledge of the Integrity Initiative:

A. Sign the Integrity Pledge and adopt a Unified Code of Conduct for Business

■ Tone from the top

■ Prohibit bribery

■ Adopt best practices

■ Implement control measures

B. Integrity self-assessment

■ Using diagnostic tools

■ Monitoring the performance in critical areas

■ Needs assessment

C. Validation

D. Learning interventions to address gaps

■ External review

■ Address gaps through learning

■ Reinforce integrity habits

E. Certification

F. Global and local competitiveness

One of the milestones in moving companies from signing the Integrity Pledge to obtaining certification is the development of the online self-assessment tool.

The online tool was designed for participating organizations to gauge the extent to which existing policies and practices are aligned with the Unified Code of Conduct for Business. Companies are also invited to use the tool to reflect on existing strengths, best practices and areas of improvement that can be used for planning and designing integrity improvement strategies.

Who should accomplish the assessment: senior management with the assistance of the compliance officer.

While the Integrity Initiative can also monitor the self-assessment of companies, rest assured that all responses are kept confidential by the Integrity Initiative.

Feedback would be appreciated; contact me under [email protected]

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