You have? Great!!
As a test, please check the guiding principles per focus area of the Integrity Compliance Framework and establish whether your management and your employees are fully familiar with them.
“We firmly believe that the sustainability of our business operations can only be achieved by adopting high ethical standards and promoting a culture of integrity. Our top management internally and externally communicates zero tolerance on bribery, fraud, corruption, and unethical business practices; complies with all the requirements of government regulatory bodies; and does not tolerate any cover-ups and falsified reports that conceal improper transactions. Management strongly supports integrity practices and allocates sufficient resources for their implementation.”
“We strive to instill a culture of integrity among our employees. The management maintains open lines of communication, particularly regarding ethical issues. All employees have the right to file complaints against practices suspected to be illegal or unethical. We have appropriate tools to confidentially receive, monitor, and act on internal and external complaints. Employees filing complaints will be protected from all types of retaliation, while those involved in corrupt and illegal activities will be subject to strong disciplinary measures. We have instituted training programs on business ethics covering all levels of the organization.”
Sales and Marketing
“Our company has clear guidelines on gifts, tokens of hospitality, and charitable contributions to/from public and private organizations and their representatives. No employee is permitted to offer, promise, or give, as well as demand or accept concessions—directly or indirectly—in order to obtain, retain, or secure any undue advantage in the conduct of business.
We abide by existing laws when making transactions with government agencies (as stipulated under Republic Acts 6713 – Code of conduct and ethical standards for public officials and employees and 3019 – Anti-graft and corrupt practices act) and commit to abide by future anti-corruption and antitrust legislations.”
Finance and Accounting
“We require all our employees to ensure that all books and records they create or are responsible for are complete and accurate. Our financial records conform to standard accounting principles, comply with SEC’s requirements on disclosure and transparency, and abide by anti-money laundering laws (Republic Act 9160) and international conventions. We pay fair taxes and comply with all laws on taxation.”
“Track record of integrity and compliance with existing laws is considered when we vet third party consultants, suppliers, intermediaries, and agents. Our company has a competitive system for procurement and does not tolerate collusion between and among our employees and suppliers. Recognizing that ethical practices are widely shared within the business community, we enter into integrity pacts with our suppliers and ensure that they understand the provisions of our pact. Contracting a third party to bribe or commit corrupt practices on behalf of the company is strictly prohibited.”
“We comply with laws and regulations pertaining to supply chain management. We do not tolerate any breaches in existing laws in exchange for undue advantage, illegal and unethical concessions, or favors. We pay correct duties and taxes based on transparent assessments of goods and services. We do not compel our employees to breach existing laws to meet the demands of our operations. Employees are not penalized for refusing to pay bribes or facilitation payments, or for refusing to engage in corrupt practices, even if it results in failure to meet deadlines or loss of revenue.”
How did the check go?
If you can wholeheartedly say that you are compliant and these guiding principles are fully implemented in your organization and are regularly audited, you can clearly demonstrate that you are ahead of your competition.
If you feel, however, that you fall under “conditional” or you “failed” and that more needs to be done within your organization to implement the guiding principles, I encourage you to contact me so that training programs can be discussed to move your organization to ‘compliant’; you can contact me at email@example.com