Lecture Notes: Anti-Corruption Ethics and Compliance Programs

Introduction

• Welcome and introduction of participants from around the globe.
• Housekeeping: Simultaneous interpretation available in French, Portuguese, and Spanish.
• Interactive session aimed at knowledge sharing and active engagement.

Initial Survey

• Audience polled on awareness and presence of anti-corruption programs in their companies.
• Questions included awareness about anti-corruption ethics, presence of programs, effectiveness of implementation, and responsible parties.
• Majority responses indicated awareness and presence of programs with varying degrees of effectiveness.

Presentation by Dr. Fabian

Overview

• Focus on implementation and execution of anti-corruption programs.
• Importance of commitment from the board, senior management, and all employees.

Key Components

1. Internal Controls and Record Keeping

   • Provide reasonable assurance on effectiveness, efficiency, and compliance.
   • Importance of maintaining comprehensive records and chronological documentation.

2. Communication and Training

   • Regular training for all employees and risk-exposed employees.
   • Inclusion of business partners in training.
   • Use of various platforms like websites, newsletters, and emails for training and communication.

3. Promoting and Incentivizing Ethics and Compliance

   • Financial and non-financial rewards to promote ethical behavior.
   • Importance of non-financial rewards to build a culture of integrity.

Detection and Reporting

• Seeking guidance and providing a safe environment for reporting violations.
• Internal and external detection methods.
• Importance of whistleblowing and protecting whistleblowers.

Disciplinary Policies

• Catalog of sanctions, procedural guides, and opportunity to appeal.
• Sanctions must comply with local laws and respect due process.

Business Partners

• Apply anti-corruption measures to subsidiaries, affiliates, joint ventures, contractors, and suppliers to mitigate reputational risk.

Public Reporting

• Transparency in how the company deals with corruption and violations.

Resources and Upcoming Events

• Various tools and guidelines available from UNODC and UNC.
• Call to action for private sector participation.

Panel Discussion

Panelists

• Representatives from Malaysia (Nuri), Tanzania (Hammad), and Uruguay (Fernanda).

Nuri - Malaysia

• Framework: Policy, procedures, systems, and technology.
• Emphasized clarity, communication, and culture in training.
• Quarterly updates on bribery and corruption risk assessment.
• Use of ISO 37001 for anti-bribery management system.

Hammad - Tanzania

• Collaboration between private sector and government on anti-corruption.
• Challenges include lack of policies and favorable business environment.
• Role of leadership in setting a good example and promoting ethical behavior.

Fernanda - Uruguay

• Implementing compliance programs globally with a focus on high-risk areas.
• Detailed due diligence procedures for new business relationships and third-party engagements.
• Importance of collaboration and training stakeholders.

Conclusion

• Emphasis on continuous improvement, transparency, and collective action in fighting corruption.
• Encouragement to sign the call to action and participate in upcoming UN events.