The Public Face of Integrity: What should companies report about their anti-bribery and corruption policies and programmes?

TBLI Conference, Amsterdam 1November 14, 2008

Reporting on Anti-Corruption Policies

and Programmes

Presented by Jermyn P Brooks

Director, Private Sector Programmes Transparency International

www.transparency.org


Presentation contents

• The Argument for Disclosure• B&C reporting survey• The case for reporting on B&C

– Scope of research– Results by country– Results by industry sector

• Good reporting standards• Best practice examples • Discussion


Corporate Reporting: The Need for Reporting on Integrity Issues

• Changing demands– FTSE4Good - bribery indicators adopted– UNGC - Communications on Progress– PACI - Highlighting achievers process– GRI - Standardised quantified

disclosures• Raises credibility of voluntary standards• Basis for independent verification


Corporate Reporting

TI's aim is to promote private sector reporting on policies and management systems for combating bribery and corruption based on accepted standard disclosures


Corporate Reporting: Scope of Research

– Desk research on 500 companies from Fortune 2000 from 32 countries.

– Company selection criteria: • 250 largest companies listed• 180 companies from “high risk sectors” -Oil & gas,

materials/mining, aerospace & defence, capital goods, construction, telecoms, and utilities.

• 70 companies from each of the 25 largest global exporting nations.

– Data sources: Publicly available company documents (documents available on company’s website, latest annual and sustainability reports)


Corporate Reporting: Results by country

0

5

10

15

20

25

30

35

40

45

50

Russia

Taiwan

China

Belgium

Japa

n

Hong

Kong

(PRC)

South

Kor

ea

Franc

e

Sweden

Germ

any

Italy

Spain UK

Nethe

rland

s

Switzer

land

United

Sta

tes

Canad

a

Source: Transparency International, 2008


Corporate Reporting: Results by Sector

Source: Transparency International, 20080 5 10 15 20 25 30 35 40 45 50

Hotels, Restaurants & Leisure

Food Markets

Transportation

Consumer Durables

Chemicals

Business Services & Supplies

Trading Companies

Telecomm Services **

Construction **

Capital Goods **

Materials **

Utilities **

Banking

Household & Personal Prod

Diversified Financials

Food Drink & Tobacco

Conglomerates

Retailing

Media

Health Care Equip & Svcs

Semiconductors

Techn Hardware & Equip

Oil & Gas Operations **

Insurance

Aerospace & Defense **

Drugs & Biotechnology

Software & Services


Good Reporting Standards

1.) Description of anti-corruption policiesScopeLegal complianceDetailed provisions

2.) Steps taken to implement the policiesScopeCommunicationTrainingHR policiesHelplines and whistleblowing

3.) How are the systems monitored?Self-evaluation processesFrequently and scopeDealing with incidentsFeedback to Board


Examples of best practice

1.) Description of Policies

BG Group– Anti-corruption forms part of a wider approach

within the company towards business conduct.

– Links its approach to multi-stakeholder initiatives.

– It does not treat corruption as only bribery, but shows an understanding of its relationship to a wider range of issues.


from BG “Corporate Commitments”“OUR COMMITMENT: We recognise that corruption can

come in many guises, including bribery, extortion and the misuse of power.

We prohibit the offer, gift or acceptance of a bribe in any form. We work to identify and eliminate facilitation payments. We support Transparency International’s Business Principles for Countering Bribery.

We support the Extractive Industries Transparency Initiative and work with governments to publish revenue payments.

We ensure that our social investment projects are free of corruption and that charitable contributions and sponsorships are honest and open.

BG Group (continued)


– Performs risks assessments: – Methodology includes assessments of country risk where the social,

political, economic or other factors related to the countries in which BHP Billiton operates or plan to operate can potentially impact on their operations, business or reputation.

– Include bribery, fraud, extortion, collusion, conflict of interest and money laundering, which in this context include an offer or receipt of any gift, loan, fee, reward or other advantage to or from any person as an inducement to do something that is dishonest, illegal or a breach of trust in the conducting of our business.

– Acknowledge importance of training for employees, management, or third parties (e.g. suppliers) on corruption related issues.

– “Source: BHP Billiton, Sustainability Report 2007

1.) Policy development2.) Implementation

BHP Billiton


2.) Implementation

BP– Includes detailed basic provisions in their

documents – e.g.: • “We will not engage in bribery or corruption in any form.

Corruption is the enemy of development and human progress, and we are committed to transparency in all our dealings.”

• “We must choose suppliers carefully, based on merit, and with the expectation that our suppliers will act consistently with our compliance and ethics requirements.”

– Presents examples and rule-based details – e.g.: • “Always unacceptable Other types of gifts and entertainment

are simply wrong. These are never permissible, and no one can approve them. These are: Any gift or entertainment that would be illegal (anything offered to a government official in breach of local or international bribery laws)…”


2.) Implementation Scope

GE– Extends policies to countries of operation. Chile

GE Anti-Corruption and compliance efforts also extend to particular countries. In 2006, GE partnered with Transparency International in Chile to develop a model compliance program that can be adopted by both private-sector and governmental entities. To date, one large business group in Chile has fully implemented the initiative, and two very important countries kicked off their integrity and transparency programs in 2007”. (Extract from GE 2007 Compliance &Governance Overview, 2007)


3. Monitoring

GE Whistleblower activity

Ombudsperson concerns by area, 2002-2006 (Extract from GE 2007 Citizenship Report.)


3.) Monitoring

BP– Report KPI.

“Every year, each business or functional team is asked to produce a certificate indicating the extent to which it has complied with laws, regulations and the code of conduct. Under this process, line managers certify the behaviour of teams under their direction, following a team discussion….”

– Submits a number of its processes and systems to external verification and comment.


Thank you !

Jermyn BrooksTransparency InternationalAlt Moabit 9610559 Berlin

E-Mail: [email protected]://www.transparency.org/

global_priorities/private_sector

Economy & Finance

The Public Face of Integrity: What should companies report about their anti-bribery and corruption policies and programmes?