TRAC: TRANSPRENCY IN REPORTING OF

TRAC: TRANSPRENCY IN REPORTING OF

TRAC: TRANSPRENCY IN REPORTING OF

Social responsibility and an Anti-Corruption Compliance Culture

26th September 2013

David CoatesSenior Advisor

Transparency International UK

At home with Ethics and Compliance

Ethical, Legal and Socially Responsible

Transparency International

• Specialist Anti-Corruption NGO• Founded in 1993• TI National Chapters in over 100 countries

Proetica

Transparency International’s approach

•Bribery of any kind embeds corruption in the system•Corruption has victims•Fighting corruption often requires collective action to achieve systemic change•Zero tolerance

Common Excuses For Paying Bribes

6

IGNORANCE “If only we'd known that it would

be regarded as a bribe…”

COMPLACENCY “We’ve always done it…”

SIEGE MENTALITY “We can only compete if…”

PRETENDING IT’S NOT A BRIBE “It was only a helicopter trip and

a five-course banquet for him and his partner…”

OUTSOURCING BRIBERY “We had no idea our agent

was paying…”

CITING CUSTOM “That’s the way things work here -

it’s different…”

INADEQUACY “We thought our anti-bribery systems

were up to the job…”

Likelihood of companies to bribe abroad by sector

8

7

6

5…

0 = Always

8

Where does Corruption Take Place?

• Corruption can also exist between private-sector parties, their proxies or agents

• Grey area between public and private sectors makes public/private distinction increasingly obsolete

UK Bribery Act

• Section 7 - Failure by a commercial organisation to prevent a bribe being paid for or on its behalf.– Critical Motivator for Social Responsibility– MoJ Guidelines 6 principles ‘Adequate Procedures’– Bad Apple Mitigation

9

Adequate Procedures

– High-level commitment– Risk assessment– Policies and Procedures– Implementation (e.g. training, communication)– Due diligence assessment of partners, agents and contractors– Monitoring and evaluation

10

Need to Merge

Questions and Thank you

• David Coates• [email protected]• +44 (0) 7768 48 66 30• [email protected]