Institutional Integrity Management Hong Kong Experience · your dirty linen in public? Food for Thought Do I develop a set of best practice for corruption prevention? Food for Thought

Institutional Integrity ManagementHong Kong Experience

Tony Kwok, SBS, IDS, JPHon Fellow & Adjunct Professor HKU

UN Anti-corruption Expert GroupVisiting Lecturer, IACAVisiting Expert UNAFEI

Regional Coordinator, IAACA Visiting Professor, PRC National Prosecutors CollegeAnti-corruption Advisor to Philippines & Mongolia

Former Deputy Commissioner, ICAC HK

Food for Thought

How much time do I give to maintaining staff integrity?

Food for Thought

What kind of example am I setting in my personal conduct?

Food for Thought

Do I care about conflict of interest?

Food for Thought

Do I exercise effective internal control?

Food for Thought

Do I have an effective system to detect early sign of corruption:

Food for Thought

Do I encourage or discourage whistle blower?

Food for Thought

Do I believe in “Don’t wash your dirty linen in public?

Food for Thought

Do I develop a set of best practice for corruption prevention?

Food for Thought

Do I have an anti-corruption Action Plan?

Every Institution, Government or Private,

should take up Responsibility of Cleaning their Own Houses

Case Study – Hong Kong Police

Squash Development & Corporate Governance

Tony Kwok, SBS, IDS, JPHon Advisor &Former Chairman of Executive CommitteeHong Kong Squash

PILLAR I

EthicalLeadership

PILLAR II

Staff Integrity

PILLAR IV

Monitoring &

Deterrence

PILLAR III

Systems Integrity

Institutional Integrity

Ethic Leadership

1. Tone from the top – zero tolerance

2. Executive Committee to formulate ethic policy, integrity strategy and action plan

3. Declaration system for conflict of interest

PILLAR I

EthicalLeadership

PILLAR II

Staff Integrity

PILLAR IV

Monitoring and

Deterrence

PILLAR III

Systems Integrity


Staff Integrity

1.Tailor made Code of Ethics for staff, players, coaches

2.Integrity vetting

3.staff ethics training

4.Healthy life style

5.Staff appraisal

PILLAR I

EthicalLeadership

PILLAR II

Staff Integrity

PILLAR IV

Monitoring and

Deterrence

PILLAR III

Systems Integrity


System Integrity1) Risk Management2) Proper Accounting 3) Procurement4) Anti corruption Clause in contracts5) Players selection 6) Coaching

PILLAR I

EthicalLeadership

PILLAR II

Staff Integrity

PILLAR IV

Monitoring and

Deterrence

PILLAR III

Systems Integrity


Monitoring & Deterrence

1) External auditors2) Public complaint system3) Protection of whistle blowers

4) Independent Discipline Committee

ICAC Integrity System

• Reasonable pay• Internal Investigation Unit – report to the top• Fair & transparent recruitment• Integrity checking• Staff ethical training• Strict disciplinary regulation：

– Declaration system– Zero tolerance

• Internal & public complaint system• Independent monitoring committee• Internal audit & risk assessment team

Hong Kong Practice Government

• Designated Ethic Officer in every government departments

• Code of Ethics for Civil Servants• Corruption Prevention Handbook for

Managers• Training/workshops• Departmental integrity committee

Hong Kong Practice Business Sector

• Ethic Development Centre• Corruption Prevention Advisory Service• Best Practices Guides• Training Packages for specific sectors,

eg 500 managers in public listed companies

• Self assessment toolkits• HKU Certificate Course in IIO

Certified Institutional Integrity Officer (CIO)

Curriculum

Tony Kwok, SBS, IDSAdjunct Professor & Course Director, HKU

UN Anti-corruption Expert GroupVisiting Lecturer, IACAVisiting Expert UNAFEI

Regional Coordinator, IAACA Visiting Professor, PRC National Prosecutors CollegeAnti-corruption Advisor to Philippines & Mongolia

Former Deputy Commissioner, ICAC HK

Anti Corruption Studies

• Postgraduate Certificate in Corruption Studies (3 weeks, for anti corruption professionals)

• Senior Executive Certificate in Institutional Integrity Management (9 days – for IIO)

Senior Executive Certificate in Institutional Integrity Management

Aims & Objectives

To equip participant with professional knowledge & skill for strengthening the institutional integrity profile of their institution, and hence enhance their capabilities to safeguard their institutions against corruption & fraud


Upon completion, the participants will be able to :1. Formulate & manage institutional ethic policy & staff

code of ethics2. Formulate, manage & review annual integrity action

plan3. Conduct staff integrity vetting4. Organize staff ethics training & development5. Expertise in risk management6. Establish complaint system & internal monitoring &

investigation on corruption & fraud


Three modules (3 days each)

1. Institutional Framework2. Corruption Prevention & Education3. Detection & investigation of corrupt

practices & fraud


1. Institutional Framework• Theories on corruption – definitions,

types, causes & effects, psychology of corrupt behaviours, cultural diversity

• Legal framework – legislations on corruption, fraud, money laundering, conflict of interest

• Strategic Planning workshop


2. Corruption Prevention & Education• Corruption prevention measures in

procurement, public services delivery, HRM etc.

• Staff code of ethics• Corporate governance• Community education• Partnership with civil societies• Case study – HK Police, World Bank


3. Detection & Investigation• Complaint system• Protection of whistleblowers• Basic investigation skill• Detection & internal audit• Fraud, money laundering, asset tracing• Writing an investigation report• Case studies


Assessment - based on an individual project report (2500-3000 words)

A study of corruption & integrity profile in an organization, covering

• Diagnose the current situation• Analyze the causes of corrupt/fraud and

opportunities• Assess the effectiveness adopted• Make recommendation for improvement

Institutional Integrity Structure

• Institutional Integrity Steering Committee

• Institutional Integrity Annual Action Plan

• Institutional Integrity Officer (IIO)

Role of IIO• Provide professional advice to the Steering

Committee• Assist in the formulation of annual action plan• Coordinate & monitor the implementation of

the Action Plan• Progress report to Steering Committee• Provide in house training• Manage an internal complaint system• Staff integrity vetting• Partnership with anti corruption agency &

others

IIO Scheme• Selection – integrity vetting• Two level training• Training for members of steering

committee• Professional training course for IIO

– Curriculum– Assessment

• Advisory Board• Governing & Accreditation Board• Role of ACA

CIO Governing Board

• Define the role of CIO • Accreditation• Registrate & de-registrate CIO• Standardize content of training course• Approve educational institutions to

conduct CIO courses

Conclusion 15 Do-able in a company

For Employers/Senior Management 1. Tone at the top & led by example2. Staff Code of Conduct 3. Conflict of interest management 4. Regular risk assessment5. Sound management and control system6. Effective Staff communication & training7. Enforce compliance & discipline


For Managers and Supervisors

8. Implement proper procedures and practices

9. Proper control & supervision10. Provide guidance to staff


For Staff /All11. Know the legal & ethical requirement12. Observe the company rules and code of

conduct13. Stay vigilant to all corruption risks 14. Seek advice/direction from management

in case of doubt.15. Report any suspected malpractices

谢谢http://www.kwok-manwai.com

[email protected]

Institutional Integrity Management Hong Kong Experience · your dirty linen in public? Food for Thought Do I develop a set of best practice for corruption prevention? Food for Thought

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