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TRAC: TRANSPRENCY IN REPORTING OF. Social responsibility and an Anti-Corruption Compliance Culture 26 th September 2013. David Coates Senior Advisor Transparency International UK. At home with Ethics and Compliance. Ethical, Legal and Socially Responsible. Transparency International.
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TRAC: TRANSPRENCY IN REPORTING OF Social responsibility and an Anti-Corruption Compliance Culture 26th September 2013 David Coates Senior Advisor Transparency International UK
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 COMPLACENCY “We’ve always done it…” IGNORANCE “If only we'd known that it would be regarded as a bribe…” 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
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
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
Questions and Thank you • David Coates • david.coates@transparency.org.uk • +44 (0) 7768 48 66 30 • david.coates@beta4change.co.uk