hello and greetings to all of you today thank you so much for joining this session we [Music] are slowly seeing as the numbers stream in thank you very much we are aware you're joining in from all the parts of the globe thank you so much we appreciate your presence here today and um we we'll start shortly maybe as you join in you can just let us know where you're joining us from in terms of location and your organization as we slowly let our colleagues join us thank you so much really really impressive to see sort of um the heat map in different parts of the map really really really great thank you all welcome welcome all thank you colleagues once again to those joining us please let us know where you're joining us from today and your organization the numers streaming in thank you so much we are very pleased to see the level of Engagement we have today great so um we'll start in the next minute so let's just give our colleagues one minute and then we can kick off cogniz of time for everyone thank you so much okay I think let's get started and um everyone else can then just join in later and they can continue from where we will be with the deliberations um just to make a quick announcement here housekeeping we offer a simultaneous interpretation to French Portuguese and Spanish and all the requisite icons should be at the bottom of your respective screens just have a check now and if you face some challenges please just drop us a line in the chat and our team will try to get you sorted out as first as possible so we have French Spanish and Portuguese available check at the bottom of your screen you should have the respective buttons in case of anything just chat us and we will respond to you as fast as possible thank you so much once again and um we hope that this session will be very interactive we of course are very thrilled to have this knowledge sharing session with our panelist today who will introduce later but we also look forward to you know a very active engagement from the audience in the form of the input and questions today feel free to use the chat and Q&A functions here here and we will of course respond to some of your questions during the session in the discussions but some of the inquiries shall be directly responded to in the chat and um also as part of starting the session we will be engaging you um you know just to get the the vibe started just to get the conversation started to get your perspective on on the topic of discussion today we shall be doing a men B so just have your phones or devices ra or your browser started and then um we shall share more details as we proceed please we look forward to a very Lively engagement um and thank you so much thank you so much for your time today we really appreciate that you are here today so we look forward to hearing from you this is your session we look forward to your engagement I think um we can proceed so just to provide um just to provide um the guidance here we are we have the minimeter here you can either scan the QR code on the right hand side of your screen or go to www.my.com and enter the Cote that brings you to the page where we are undertaking this um poll live poll yeah I see from the sh of um hands there that connection is working well we have couple of people joining in so let's try get there and just do a quick round of questions there just to get us started okay the first question are you aware about the concept of anticorruption ethics and compliance programs and they Us in business we are curious to just know the level of understanding in this area just to sort of you know put ourselves into perspective as we proceed yes thank you very much thank you very much of course we're very cognizant that we have AAS group here today with most of you being um representatives from the private sector so thank you very much as yeah we can can see there most of the people there um have a yes and uh couple are unsure of course we shall get to understand this great areas later and what we mean by all this um topics of discussion today yeah thank you so much thank you so someone requested to have um if we could just have a quick um sharing on the chat on the QR code and the Cote thank you okay um let's proceed please to the next question um does your company have anti-corruption ethics and compliance programs in place do you have this currently in existing in your company and of course owing to the fact that you've seen a couple of yeses being the majority response um this is a good place to understand where we lie does your company have Antion ethics and compliance program in place yes I see there's a huge number in terms of there's a huge correlation between the previous yeses and the yeses here almost aligned which is good thank you so much thank you so much for everyone responding please respond on the Mente thank you it helps us to track and sort of have this nice visualization okay so we have majority of yeses super okay yes no also curious to see about the no and yeah this is something we can follow up on later thanks please let's proceed to the next question so if present um how if is your company in implementing this anti-corruption policies and expectations to employees does your company implement this things well and doesn't communicate well to the employees how does this happen in your organization we have four rankings there from four okay good and great okay thank you so much we've seen all the responses coming in yeah thank you thank you so much yes I see the numbers are also quite um similar to the um in terms of um the total figures to what we've had previously so yeah most most of you are between okay and good of course much more can be done thank you so much this is a very good um break into our session as we um commence our webinar today okay thank you so much so the last question is who is responsible for the implementation and execution of anti-corruption ethics and compliance programs whose responsibility is this for the execution implementation of this programs that you discussed who do you think is responsible for this okay majority of you are with Senior Management okay yeah we see employees there government thank you so much again please try and respond on M because the chart might not be really monitored as far as this exercise goes thank you interesting yeah I've seen a comment that says everyone which is also an interesting response and we'll hear on this later okay thank you I think with that we can we can move on now and thank you so much for for your engagement on this exercise um it really helps um to just get the room started and uh I'll just do an introduction of today's deep live session and the topic of today is from policy to action implementing anti-corruption ethics and compliance programs in your company so what will happen is we uh will'll have brief introduction into the session and then which will be followed by a presentation by um uh the un uh Global Compact and then we will have panel discussion where we have three Representatives our distinguished panelist who will um give us more examples about you know what what's the the topic of the day and they have this key insights so without further Ado I welcome you all to this session and I will proceed with introduction so my name is Benjamin marichi and I work with a private sector team at the corruption and economic crime Branch at UNC where our key Focus really is fostering um uh business Integrity in the private sector globally so this deep dive virtual session is a product of a collaboration between the United Nations office on drugs and crime unodc and the United Nations Global compact UNC on behalf of all I welcome you all to this session today and thank you for your time and interest and we of course encourage your active engagement throughout the session and of course again I'm cognizance that we have a diverse group here and the larger percentage is from the private sector so from this topic from the topic of today you can get a sense that this session is something within a Continuum indeed this is the first the fifth session of a global series inspired by the UN Global compact management model and we have had prior sessions where we've discussed a range of topics from Integrity driven leadership to corruption risk assessment to defining of policies and the first recently concluded thematic session on the gender dimensions of business Integrity the event brings together diverse perspectives you know providing a space for interaction dialogue and knowledge sharing and the webinar series as well enables the sharing of good practices and tackling of common challenges through collaborative action in so doing we have the enhancement of the public private coroporation and the upscaling of effective approaches all the World's bus business Integrity so all these sessions that I've mentioned are available on the unodc business Hub which I will also touch on at the end of the session and just to note that today's session will be recorded and will also be added to a list of resources that we have on the Hub um in due course I will invite uh Dr Fabian fromc who will give us a presentation of course he'll introduce himself tell us what he does ATC and give us um the technical presentation from the UN Global compact thank you very much Dr welcome please thank you very much Benjamin I'm happy to join us today um I Amo I am the coordinator of anti-corruption programs on Collective action Global compact I have a PhD in politics at P University and I have worked for more than 10 years in the United Nations system on anti-corruption topics basically in UNP unodc and currently un Global comp thank you so today's presentation is going to be focus on implementation of anti-corruption programs execution and implementation of anti-corruption programs is very important because it depends on the commitment of the board of directors the Senior Management but also of the bodies the company should develop a ro to carry up its own anticorruption program and the anti-corruption program involves policies and procedures that aims addressing corruption risk pursing opportunities reducing and mitigating negative impacts and enhancing positive impacts in the case of implementing anti-corruption programs is importance as I say the commitment of the board of directors and the Senior Management so I'm going to talk a little bit about seeking guidance detection and reporting of wrongdoings addressing violations application of the program the anti-corruption program to Partners as these are key issues when you are analyzing how to implement anti-corruption programs and to make them effective in your business so the program must be effective efficient and sustainable it should be ensured that the anti-corruption program is implemented executed and monitored on an ongoing basis basis when you are answering the questions regarding to who is the who is responsible to implement the anti-corruption program the rule is that is the Senior Management of course but it's good to bear in mind that the employees also have an important role to play and we are going to see why they have a relevant role to play and why they have to be involved in all the measures of of by the organization to implement the anti-corruption program so responsibility for overseeing program rest with the board of directors the compliance committee and compliance officer or an audit or Ethics Committee but it's important to be in mind that the Senior Management has to implement execute and make it effective the application of the measures that have been ad adopted by the company to make effective the anti-corruption program so we have internal controls and Rec Court keeping as an important component part of the anti-corruption program internal controls provide resonable Assurance of the Effectiveness and efficiency of the company's operations durability of its disclosure practice and its compliance with applicable laws regulations and internal policies if you have a good system of internal controls you will be able to avoid be externally exposed to reputational damages so it's important to have good measures within your company to be able to control and to keep inside the organization any risk of corruption and have the measures to be able to control and diminishing the risk of the corruption risk materialization so it is also highly recommendable to have RS and Records it's very useful because you can have evidence in case of weaknesses and regulatories reg authorities are identified within the organization they don't not only refer to financial transactions but also in contracts delivering receipts so it's very important to have all the information as much as possible you should have back of the documents you should have record of all the transactions electronic documents and and have a and special protections to some kind of documents for instance um establish that an statement like not to destroy before the deadline and such kind of statements are very useful to keep the information with records in order and it is highly recommendable as well to have all the documents organized in a chronologic chronological order so all information is important because in case of an inment the the evidence is so relevant in order to prove that there was a bridge of any internal R within the organization and this is a relevant topic also the communication and training training is so important we really have to know that we have 882 people with us today so training is paral importance it should be provided on a regular basis to all the employees or the most exposed employees some sometimes you think that is the higher level employees that should be trained but actually hold employees because within organization every single employee has an specific role and the organization it should develop different processes different activities and there are different employees in charge of each process and activity so there are many risk within organization in different areas in different processes and in different activities so it's very important to train as much employees as possible on these topics on ethics and anti-corruption topics and the training should include also business partners it's very relevant because you can be very careful with your measures within your organization but you could be in a high level of exposure because of your partners you can have reputational damages because the misbehavior of your partners so you should includ your partners in your training and you should apply a criteria for recruitment criteria for business relationship I'm going to talk about it later and Link the trainings to special locasion like the for instance the anti corrupt International anticorruption Day end of December we have trainings in a flagship moments and it's very important just to create a culture of ethics and business Integrity the evaluation should be done frequently you know that the fight against corruption is not not um a Sprint it's a marathon so you have to keep working on it so you have to on a frequent basis you should be assessing your controls you should be assessing the the level of knowledge of your employees it is important also to have channels for training and communication like the websites and newsletter self learning emails all these tools are very useful to reach us much as possible and it's highly recommendable to have an standardized training at least once a year to train the EMP about ethics and anti-corruption but of course if you can do it within your organization more prly it will be great one important thing when talking about implementing anticorruption programs is promoting and incentivizing ethics and complies the company may consider an incentive scan why because most of times the Senior Management focus more on the sanctions rather than on the incentives and the incentives are very important to promote a culture within the organization and to know that behave in an ethical way is something that should be rewarded so there are many types of incentives like Financial Rewards and non Financial rewards Financial rewards are like for instance salaries increase bonus promotions gifts gift cards for members they can be privileged access to business opportunities and preferential business terms and there are also non-financial rewards like recognition rewards Awards Publications in the Press access to forses recog recognition by management so it is highly recommendable to adop as much nonfinancial rewards as possible because it's important to create as I mentioned the culture of the organization about business integrity and ethics and it is not recommendable to just refer to financial rewards and to link ethical Behavior with you know profit because it's not about profit only but it's also about um a change a change of mind uh adop a high level standard of ethics and integrity so incentives are very important if you have Financial Rewards or non Financial rewards are very important because you have to encourage your employees to you know is is to adopt all the high standards High ethical standards of the organization is like them you know carrot and steel the carrot is the incentive are the incentives which should be promoted by the organization and this St should is related to the guidance detection and reporting of violations detection is a positive sign that the program is working and should not be perceived as a FL system this is very important because sometimes you think that you have detection system within your organization and you find out that there are some symptoms of corruption is a bad sign actually it's not actually it's a good sign that your cont and your pools are working properly and that you are able to adopt measures to avoid a risk of corruption being materialized in the organization so it's very important the detection systems and and it's important to understand that there are different levels one is seeking Guidance the organization should provide a safe environment for reporting a risk of corruption or or the tech violations of the ethics of the company so the company should provide guidance should have a person in charge of dealing with the um whistleblowers reports and violations of internal rules of the organization so it could be your organization can hide an external provided I will say later why I'm referring to the report violation so it's important to have at least one person it could be in house but it also could be H to provider to facilitate the reporting of violations so the second point is detection of violations detection of violations could Bey internally because you have some reports of corruption mular organizations you have insiders that can report um issues related to corruption or risk of corruption but also external the problem you have when you detect corruption externally is that you know the the information is outside the company and everybody knows that you have a problem dealing with corruption with organization so it's highly advisable to create as much as internal controls as possible to be able to keep all the the corruption scandals scams within the organizations and to have specific controls to handle with them um the third point is we report violations whistleblowing whistleblowing should be included as a core subject and in Communications it's very important to promote um whistleblowing within your organization it's very positive because the Whistleblower is aider of your company and The Whistleblower is able to understand what is actually happening inside the company most of time if an employee knows exactly what is what is the problem what is the process affected by the corruption issue so he will be able to communicate such issue and the senior manager will be able to take the necessary measures to avoid the risk of corruption so it's very important to promote whistleblowing it's very important to create some safe spaces to report corruption scems or corruption issues within your organization the the whistleblowing The Whistleblower should be protected by the company not only the information that he provides to the Senior Management about the corruption Scandal or corruption but also the person itself should be protected effective and and the information by theer should be Tred in a professional waying the and should be provided should be provided a safe space and should be provided as safe space to report corruption issues very of time it's important also to understand that it's important to have a disciplinary policy a disciplinary policy involves three key issue a catalog of sanctions guide on procedures and responsibilities and an opportunity to appeal please let mind that anti-corruption doesn't justify violations of the U process of the good faith principle during the entire process of the disciplinary policy when you are going to materialize San for instance you should be in mind that you have you should be very respectful of the Vie process you should be very respectful of the right of the syic here and it's you have to understand that the good principle the principle of good faith should be present the entire investigation and the en process that's why the opportunity to appe is so important so applying sanctions sanctions may be directed at employees finds reduction and remuneration some doesn't allow such kind of actions so it's important to know that your measures your sanctions are not against the law they should be aligned with the law they should be in accordance with the law they should respect the public law of your country should be respectful of the L laws so in some countries it's not important it's not possible the reduction remuneration and also transfer to a lower position sometimes it's against the L but the idea is that we have to the sanctions and the sanctions have to be in accordance with your local law with the national law because it's public law so the notification of violation is so important it's relevant and to have a clear protocol about how to proceed in case of a valuation you cannot surprise your employee with new procedures new measures but they should have a at least knowledge what happen in case of a violation and this is very very very so the sting of the medal actions is the detection of an attempt of violation is an opportunity to identify potential areas for improvement improve the internal control environment increase communication and training or adjust the entire disciplinary policy incidents should be documented for future monitoring there is something which is the the importance of communicate to the entire organization what has happened and in order to avoid in the future such kind of wrongdoings happening again so the incident should be well documented and well should communicate the entire organization to avoid the incidents happening business partners are so important because if you adopt a good anti-corruption program but if you have business partners that are not as a responsible as you in adopting such measures you can be exposed to reputational risks so you have to bear in mind that your programs should be promoted among your subsidiaries Affiliates joint ventures agents and intermediaries contractors and suppliers so there is a different level of control on these different business partners but disregarding the level of of control that you have on them is very very and highly advisable to use to for um high level standards the levels the standards of business integrity and transparency and integrity that you have within your business you should promote with your business part Partners in order to avoid reputational risk you don't want to be involved in a corruption scan because one of your business partners have low standards of anti-corruption in progress so finally let conclude public reporting is so important summarizing I can say that it is important to involve the board of directors in all the process don't forget is a the fight against corruption is Marathon it takes time it's an ongoing process so the the you know T from the top the the top of the organization should be involved in all not only in the RIS assessment not only in the preventive measures but Al also in implementing um measures to sanction violations of the Integrity anti-corruption program so it's important to be clear with employees it's important to provide clear information about the procedures it is important to establish clear information about what is the consequence of a violation of the anti-corruption program so that's the most important thing is public reporting is important public reporting is also important to let others know what your company is doing to corruption but also how your company deal effectively with violations of the code ofs of the anticorruption program or the integrity and rules that oranization have so thank you so much that's my time thank you thank you so much Fabian um maybe what you can um touch on next is just maybe what kind of resources you have from UNC and maybe just discuss a bit about uh what we have upcoming in relation to the events youc and we have many guidelines tools and on these issues that should be ready you have time to take a look at them because they provide detailed information about what I have approach in this brief presentation for instance the anti-corruption ethics and compliance program for business the Practical guidec is a very good docent have a lot of information it contains checklist about what you have to including your disciplinary policy what you should have in learning mind where you are developing your Wile protection scem all this information is included in this documents and you also have the 10 principle against corruption the reporting guidance on the 10 principle against corruption it's document that you know the 10 principle is related to the fight against corruption so it includes an a specific um protocol about how sanctions should be applied how measures should be applied and how they the controls can be improved within your organization to be effective in the fight against corruption so sources that you can just download from the websites ofc or so what's coming we have the private sector Forum you know is the 10th anniversary of the conference of of the United Nations conventions against corruption so we have the conference of State parties and in the frame of the confidence of the state parties on December 11 and 12 we have the private sector forum is a very important scenario because we have companies and representative from the private sector that are going to discuss key issues related to anticorruption you know and the last Trends on the fight against corruption so we are going to have many sessions technical sessions and the is just invite you to be with us in the in Atlanta in the conference of State parties is the 20 universary and it is the first time that we have an special event private sector Forum just to have private sector discussing the key topics new trends about anti-corruption and integr and business Integrity but also I want to invite you to sign the goe to action K 20 the C reaction is an appeal of companies for governments to underscore anti-corruption and government it's free the link has been shared by my colleague an and please join us in this initiative it's very important it's important because it's a way in which the private sector say to the government that they have a real commitment not only on paper but a real commitment to fight against corruption and to support the anti initiative and the promotion of business Integrity in the entire world so it's a for free you can sign the call to action to show that you are really committed with the business integrity and don't L this opportunity the deadline is December 1st so please join us in this important initiative in the go to actions 20 thank you so much thank you so much Dr fabbian and um maybe just to add on something before I forget the deadline for um submission of your application for the private sector forum is the 30th of November so I really encourage the private sector Representatives here today to just um sign up as soon as possible if you're interested in attending this and yes we look forward to also engagement on the call to action thanks so much Dr Fabian and you've um you've um really put us in perspective of this discussion and we're really um appreciative of your Insight and I think what I'll do I had some questions for you but I think maybe what we can do is just proceed to the next step and um if we have some time left then I could um come back to if that's fine so thank you thank you so much for that so increasingly um we've seen a number of companies you know demonstrating ethical leadership by implementing effective anti-corruption ethics and compliance programs in internally and following the development of action plans based on risk assessment the next expected shift involves uh moving from policy to implementation of these strategies and policies throughout the company and across its value chain and essentially having an effective integrity and compliance program designed to support the business in making important decisions that are aligned with its corporate goals and strategy is crucial for a business to successfully Implement various policies it's essential to the capacity building training and communication of the policies to employees and other parties within the business additionally an internal control system should be established with reporting channels such as a confidential whistle employing mechanism in place to encourage employees to report potential misconduct without fear of retaliation and in so doing prevent and detect wrongdoing which really brings us to the next um um segment in our presentation today uh we have a very good set of panelists from Malaysia Tanzania and Uruguay and our panelists today will help us engage in a dialogue on how to unack how companies can essentially engage in processes to execute their strategy throughout the organization from an anticorruption perspective I welcome uh Miss Nuri Mr hammad and miss beranda and May maybe just to start with Miss NRI from Malaysia if you could just briefly introduce yourself and tell us more about what you do and how you were situated within today's topic and then I can follow up with some questions for you welcome you have the floor thank you Benjamin and hello everyone it is actually about 11:42 p.m. in Malaysia I'm very happy to see some of my Malaysian colleagues join this uh forign forum and hope we can stay awake to the end of The Forum so I am thrilled to be part of this forum dedicated to the vital Journey from policy to action when it comes to anti-corruption ethics and compliance program in a company I currently serve as the integrity and governance uh unit uh office uh head of integrity and governance unit and also the compliance officer for Maxis Bart and we are actually a Telco uh company uh in Malaysia and um where in that company I am deeply involved in the strategic planning and execution of all the compliance and integrity program and as you can see at my background uh we are making sustainability part of our DNA in which we are upholding ESG principles as well so with almost 20 years of experience as a certified Integrity officer because in Malaysia we do have uh prime minister's directive in terms of establishing integrity and governance unit in government link company government link Investment Company and also private sector so there is an academy that is hosted by the Malaysian anti-corruption commission they will actually train and certify uh compliance feruni and there there is an association as well it's called The Association of certifi Integrity officer and in which the regulator which is our CCC the Malaysian anti-corruption commission will monitor our progress and we will be called to a meeting twice a year to discuss on our progress uh and what do we do in the company so uh I had the privilege on working with Comprehensive anti-corruption and Ethics program for the nation as well way back in 2010 with the national uh key res area and now uh in Malaysia we also have National anti-corruption plan that is coming coming to an end and we are coming up with another strategies to combat and eradicate corruption so it is a a multiple stakeholder initiative that has been taken place in our space in Malaysia between the government the private sector and also the Civil Society so uh currently it is my firm belief that effective compli is not just about having the right policies in place but it's also translating them into a culture of integrity and making sure that it's embedded in their thoughts and mind and having the Integrity that is doing the right thing even when no one is looking is very crucial so uh I am passionate about all the subject uh you name it corruption risk assessment uh anti-bribery management system which I'm excited to share later in the in the discussion and also I've been involved with a lot of uh discussion and panels uh in in local and also International level and I'm so happy to be here and thank you thank you uh Benjamin for inviting me for tonight I hope I look forward to connecting with all of you and being part of the community that is dedicated to Turning ethical and compliance to aspiration to the real world results thank you Benjamin over to you thank you so much Nuri honestly I think um we're really privileged to be having you and of course knowing the time in Malaysia now we we really really are grateful for you and your colleagues who were joining us from um that part of the world thank you indeed for just um situating this um conversation within the context of your company in Malaysia and maybe just to um to just follow up on on the brief you've given us um I'm just curious um what kind of steps do you have or what kind of steps are taken by the organization by your organization to ensure that the employers actually are aware of and are trained on the um companies anti-corruption ethics and compliance policies and uh procedures and the second one maybe if you could just just um respond on this as well is how your company actually monitors and assesses compliance with anticorruption because it's one thing to do and one thing to actually ensure that things are happening and what measures then do you have in place for um reporting or violations on on on this policies thanks okay thank you Benjamin for the question there's two questions so I must remember to answer it structurally so basically before coming up with anti-corruption program in my company what I have done is I come up with a framework so in the framework normally it will consist of policy having the right procedures in place and with the system to support whatever policy and procedures that you have already had and if you have an additional resource you can opt for technology for example if you are doing due diligence you can op for external uh due diligence provider to do all the screenings for your company for the third party and also for your internal staff and also uh most importantly is on the people and culture for for my my company in Max say and also the company that I have joined before which is uh an oil and gas company and I was with the regulator so most important thing is education uh which is training and communication it is very critical for any of the policies to be communicated clearly give them the clarity give them the support make it simple as possible because you have to add so to every training that you do and make sure that is uniquely designed for each of the stakeholder because it cannot you cannot always design a training that one size fits all kind of you know the same training for the employers then you suddenly want to turn that training to the third parties it will be different the tone will be different even to the board directors I must share with you this morning at 800 a.m in the morning I just had I just conducted a training with my board of directors of Maxis perart and at 8:00 in the morning I made them understand talk about anti-corruption talk about culture talk about commitment and also at the end of the training they have to say a pledge which is the Integrity pledge it is something that it has to come from tone from the top and echoing from bottom up so that means the clarity of what we are trying to tell our people for example if you're having some sort of gift policy you have to make it clear as simple as possible that they must declare and the general rule is to say no to refuse and you know what are the exceptions if there's any and then make sure it is return in a simple language do not ask your legal people to draft the policy because it will become very complicated make it as Layman word as possible so that people can just remember in a simple manner okay what they need to do if in such situation in providing and also in receiving gift in uh the policy and plus you make it simple for them to know where to declare if you have extra budget put in the system uh you know make use the technology digitalize it make uh use a simple few buttons for them to declare who is it from what is the intention what is the value so that we have transparency in terms of reporting what has been received and what to provide make it easier for them but most importantly do not just communicate within your people you need to also communicate to the third party so they understand these are the culture these are the behavior that we want to have and established in our company to ensure that we continue doing business in a clean uh business ecosystem without corruption and you know it the the the the sustainability of the business will be there and we can continue doing business together so that kind of narrative and culture should be embedded in each and everyone in the company and also uh to those people who is your business partner and even to the government because people always have the perception when you deal with the government or public sector it's always a rate flight but actually if you know and you acknowledge the red flag and you come up with the right remedial action to manage the red flag to minimize the risk then it would be okay for example if there are government requests for sponsorship or donation you should come up with a process that is to everyone transparent and have someone accountable so it has to be documented it has to be collectively agreed it has to have a criteria and it has to be clear so when you respond to such request you can say okay this is our company's policy and we don't want to be perceived as contributing politically so hence it's very important to make sure whatever that has been uh discussed or whatever is minuted properly is discuss at greater length and make it into policy turn it into a good procedure come up with the system to support it and communicate that's the magic word so back to Malaysia now we already have this uh corporate liability uh provision that has been uh enforced since the 1 of June 2020 so companies are held accountable if they are involved in briy in providing ratifications so and the only defense mechanism that we have for business community in Malaysia is to make sure that we have adequate procedures and the government have actually give us the guideline but of course we don't know we never know how adequate is adequate for the procedure so how do we measure it like in Maxis I have no idea how much procedures how adequate all the controls internal controls I have put in place so what I did I opt for the system which is called the iso 2701 because it's an international standard it will give a check and balance mechanism where there is a an external audit there will be a stage for management review and all the reports are done in a such a systematic way within the requirements of iso so the measure does not just stop there because the system itself doesn't confirm that corruption will not happen or bribery will not happen but at least it will become a preventive measures to minimize if there's any such exposure that will be happening in in the company so far after 3 years I must say uh it's an endless effort to keep on improvising enhancing all the internal controls so what I did in my company every quarterly we will update our bribery and Corruption uh race assessment and uh we have a dashboard in which I will have the access to all the divisions and department and we also appointed compliance champion in every Division and Department to become our ears and eyes and also to they hold some kpi in which I will guide them throughout the year I will train them to be uh my own compliance champion and of course we we when they are stuck or if they need help I will always uh assist them accordingly and provide them with uh enough training and not just the training will not just come from me uh I will also assign them to go out and seek for further knowledge because it's a learning journey in terms of you know making sure that our system works and another measurement that we did is uh just recently what I did uh I I did a survey to measure effectiveness of whatever culture that we have in the company it's not just according to the checklist according to the adequate procedures or whatnot but what we want to measure is beyond Integrity their willingness to speak up if they uh come across any misconduct or if they sense that you know somebody try to solicit something so we try to uh measure uh their willingness and also their compliance level and we also ask them whether do they agree if enforcement and compliance is weak in the company so it's a twisted question so everybody when we had the session because uh what I did I gather small groups of people uh every week over lunch because they a bit more relaxed and and they can think uh further and less of me talking is more of them sharing of their uh work dilemas and challenges and then we also try to get the respondent to respond to this the curated uh survey question and the result was amazing because I did the same survey last three years and when I measure it I can see there's an improvement 90% of culture change which is a great success yeah wow I think um we we can all agree this is really phenomenal and I've been um seeing some of the responses to your intervention and and I think thank you so much for um you know your your Enlightenment of us and just giving us the example from your company I think there's one there's a question which is related to your presentation later and maybe um from the audience and I I'll come back to you later so thank you thank you so much for your intervention um now thank you so much um and now move on to Mr hammad from zanba Tanzania uh please introduce yourself and uh what you do and how this topic of today relates to your work thank you yeah hello uh good evening good morning yeah good afternoon everyone here uh thank you so much uh Benjamin and I would like to uh so thank you once again for putting us on board in this session but my sincerely uh gratitude for uh Madame who has just finished her presentation I think it was a ey opener it was a mind blower for all of us here of how things are happening in in Malaysia when it comes to anti-corruption especially from the private sector perspective and uh this I think has set the ground has set the flow on how we can proceed with these sessions but also how we can learn from from one another I understand we are multiple from multiple backgrounds from multiple various economy economic levels so we can learn from uh one another here from large economies to to small economies like like ours so just as a as a brief introduction of mine uh I represent the Zanzibar National Chamber of Commerce which is the umbrella body of the private sector in Zanzibar and uh we are about 800 people here I'm sure some of you may not know what zanba is so Zanzibar is part of what it makes Tanzania Tanzania is the union of two countries formerly tanganika and Zanzibar so zanba still maintains it uh semi-autonomous status so we run our own things when it comes to businesses when it comes to tourism and other other other other things economic things but otherwise internationally we are part of Tanzania so as a as a umbrella body of the private sector in zanba we work very closely with the with the government in different angles uh including the anti-corruption and the economic crimes we work very closely with zanba anti-corruption and economic crimes Authority uh for many years now the private sector we have formed the committee which is known as uh zanba integrated strategy on anti anti-corruption and economic crimes work very closely together in terms of training uh in terms of capacity building I appreciate Madame Nuri who uh who has extens extensively uh spoken about the importance of training of uh different stakeholders in different perspectives so for that perspective we work very closely together with with the government uh on training our people especially the private sector we take the the role of training and capacity building of the private sector when it comes to the issues of the anti-corruption and the economic crimes uh but we also work with uh Revenue authorities in in in zanba to promote uh ethical Behavior ethical ways of doing businesses so we have uh suggested to the revenue authorities in zanba for example to award those who are paying uh taxes voluntarily with no with no uh pushes from the government and it has done from last year it has awarded some of the business people who are uh really uh obedient to the rules to the to the regulations of uh tax payment but uh there are some challenges still we are facing as a as a private sector also as a businesses as small business in zanba for example uh we heard from NRI she spoke about the systems that are available in Malaysia in running businesses in running the private sector in Malaysia so in many private sector organizations in Zanzibar and in Tanzania there is lack of uh this system there is lack of uh anti-corruption policies for example so in many of our organization uh you will find some uh operational documents operational manuals and policies but you'll miss uh the anti-corruption policies for and regulations for example so this is one of the areas that I see is lacking from our running of businesses but also on the side of the government you see there are these anti-corruption policies and guidelines but the implementation is not there so once there is lack of implementation of the policies from the government side to push it to the private sector then it's difficult to get uh the private sector to be compliant with those regulations because there is lacking uh the the enforcement of the policies uh but another thing that uh it's a challeng is for the private sector uh in supporting the anti-corruption movement is the business environment itself because we all understand here that the private sector is pro profit they are there for profit they want to make profit and uh for them to make the profit there should be a conducive business environment for everyone to play its their role to get their benefit what they they they want but also to pay their dues to the government so if the business environment is not conducive for the business people then there they will find their way to get out of that and make their profit that is why you find in many instances there is smuggling of some products from the island of Zanzibar to other parts of the Mainland or even to the other side of the country which is Kenya and this is because of the business environment that is uh is not supportive of doing uh I mean in Integrity in businesses uh uh I think I will stop there for now but one thing I would like to insist is that there need to be a transparency uh in in in in doing businesses but also in formulating our policies and implementing the anti-corruption policies because you find sometimes the government makes the policies without involving the private sector the policies are for the private sector to as as implementers they are there for us to implement and to abide with but if we are not part of its making then it becomes difficult for us to implement them but also uh you find sometimes there there's lack transparency uh for instance uh we are all there for supporting the government in uh fighting corruption and economic crimes but you always find uh for example there are people who are against the rules against the laws but you find no one being held responsible for for that so it discourages people to continue supporting the anti-corruption movement so this is my call for all the governments especially from the developing countries to be transparent but also to put in place uh the conducive business environment so that everyone uh is supportive for the anti-corruption movement thank you very very much thank you so much um hammad and it's um really interesting to to sort of get your Insight from from Zan of course being a smaller Nation there and uh maybe just to mention that yes of course I agree with you in terms of um having this sort of um um interaction with the government so they can also involve all stakeholders uh within um sorry during the uh development of these policies but I think also something else just to complement meant on your point is for us as um you know the private sector just basically having things in check within the organization because this is sort of like the internal um internal mechanisms within us and maybe this is where I want to ask um an additional question just so you can maybe bring out some of these things uh what challenges because you represent an umbrella body uh what challenges are inherent to implementing this anti-corruption policies you know ethics and compliance program for small and medium businesses and the second question is what do you see the role of leadership and management being you know in setting an example for ethical behavior and compliance you know with the anticorruption measures maybe in just two minutes thank you okay so I think I have addressed the P the first part of your question when it comes to uh challenges to msme uh but for the leadership part now I think the leadership plays a significant role in setting example of fighting anti-corruption so this spans in all levels of the the governance from the government side but also from the private sector side and from the private sector side I speak of uh for people like myself the leaders of the business organizations but also the leaders of the Enterprises the leaders of the the the the corporates the business corporates so we play a significant role in setting examples for our for our employees and for our colleagues in our workplaces so I think it's very important for us to show a good example is very important for us to convene uh trainings to convene messages like this what we are getting here to convene to our colleagues so that they are all aware aare of what is happening and how we should do our businesses in an Integrity manner so that we are all respected and once uh you show a good example to our government and then this is where they become uh lenient they become supportive of what we are doing and then we are becoming one thing in uh raising our economies and building our economy together so that should be my feedback to your to your second part of the question thank you so much hammad really really thanks and maybe what I can add to just complement as well is um by signing the call to action that um that Fabian presented um this is an anti-corruption call from businesses to governments and of course it helps to fully implement the UN convention against corruption you know strengthening and it builds of course to strengthen Integrity within our economy so thank you so much hammad for your intervention we really appreciate it so um thank you moving on thank you thank you so much sorry that was a l there so moving on to uh Fernanda please uh you have the floor um just brief introduction and um let us know how you situate yourself within today's topic from your organization thanks okay thank you very much thank you for the invitation toight Nations to you Bening and Florian for me it is really a pleasure to be here with the so relevant audience and an honor a pleasure to share the floor with so distinguished colleagues which I was hearing and I learned a lot so thank you very much here in uru is midday so I am having let's say it's fun because I am full of sun yes so it is the perfect moment to talk and it's I am honored too because I work for a Sharman company that is soch solar wind technology in in English is solar wind technology so it's goes hands to hands yes and also I am really happy because this week in uru we are receiving an energy International Energy conference from olade and Irena so really happy just to be talking about anti-corruption in that frame yes just to tell you a bit about myself I have been for more than 10 years working in sitech as a compliance officer I have started from Euro white then to Latin America and then the global from an international perspective in charge of compliance that means also anti-corruption and Es that goes hands to hands with sustainability and equator PR principles to comply with the World Bank I have developed from scratch the compliance policies and the implementation of the process and our sustainability policy is sust we think that sustainability growth is only possible if we combine it it with integrity and we see Integrity as something transversal yes to all the company but also to our stakeholders and through the whole Supply change that means not only our Direct business clients suppliers but we also work yes since 2014 in trying to create Collective actions and not necessarily being ourself directly involved but just trying to merge yes different interests when we detect some issues in connection with corruption for example in uru we have helped to create and Collective actions in the Customs broken agency in uru and so we are on that path in a way I have to be honest with you I am B in uru uru is one of the best countries after Denmark and so one but in Latin America we are hands to hands with Chile in term of transparency International transparency index we know transparency index shows the perception that not necessarily means what is really okay but we have a really good reputation in uru in term of Corruptions today morning I was also in a Uno event because we are working in supporting a a project a draft project to support uru yes to create an anti-corruption law to regulate the public the private sector because up to now we only have law in term of corruption in the public so we that is the path where we are going on in uru and also just to give a perspective and introduction of how I have implemented yes the compliance issue here in sovc we follow the United Nation Global compact management the will model with Sixx six steps just to commit commit just the worth then the middle management yes to asset that means just to identify the risk through risk assessment extra territoriality risk assessment yes I don't know if I have already explained to you that we developed huge renewable energy projects where the majority of them we sell them into the government that means that we go into B tender process which means plenty of risk yes and we really follow a lock book of how to deal with the government during that process and we also have um soch Integrity policy how to do it how to throw how to create Integrity together with the government yes of course there are certain countries where we have a small spot Market where we sell the energy to particulars okay but that is a really low percent so the risk goes directly into the public sector P public and private in the Rio de La Plata between Argentina and urugay we said that the tango and special dance we dances in two public and private sector yes so that will be we put a lot of conscious in the risk assessment and the Bri risk assessment in connection with tender process and in that Den with the public sector the abilitation of of authorization environmental social authorization to do the prefac abbility projects to start with the construction with the operation and so on even though we sell the project ready to build but we comply yes by that way with equator principles yes so we need to follow all that we just give the security of the project until the commission face due to that the anti-corruption policies it is a huge projection yes for the project in connection with the government community and of course the whole L change and the different stakeholders which include of course environmental NG commercial eras and so on so we were in the phase in the stage two assets then in the three one we Define yes once we have the risk assessment we know the concepts we do a r um hot map Matrix where we defined our head point we take care of them and thanks to them we start to Define how we are going to implement our compliance project I I go into the fourth state that is Implement then the five how we are going to measure it and then how we are going to communicate it we have a global compliance perspective but we adapt it into each region and into each country because each country is different yes not only by the way we sell the energy but also about the risk for example in uru and Chile where we should be proud about the good perception of corruption we have a huge risk that is conflict of interest yes specifically in urugai well we have a very low population what does it means that means that we are friends of of all so we work a lot of that and I think that is the great or which is really I feel pass passionate about that because the easier way will be okay don't do it but that is not the way to proceed of course where there is red risk of course we don't do do it but the majority of the time it is yellow how we are going to handle with that situation yes and then we start to implement a policy so that fible conflict of interest it's not going to be manifest yes and then also if you allow me I will share some academic perspective because I am also compliance Professor so always I try just to merge something the yes Fern thank you thank you I am happy to if you have some questions I am happy to collaborate yes thank you so much so I'm I was just saying that yeah I was I was asking you to if you could summarize the intervention you wanted to give but maybe I can just ask you a question and you can see if if this fits into um uh maybe what we have in mind and it's basically asking you to describe it it's very interesting because you mentioned about your engagement in in some of this you know highrisk regions or Industries or interventions and dealings with the government so the question is just if you could describe any specific um uh due diligence that your um procedures your company follows when especially entering into new business relationships um in in in these highrisk areas and how your organization engages with the third parties while promoting ethical uh business practices throughout your supply chain and um and also in connection to this is how can this parties then be held um accountable for this unethical Behavior if at all yes perfect thank you yes we just start to identify the kind of transactions we are working on because we really when we start you know the way of doing business was quite simple let's say it yes but as thing times goes by and after covid and so on things are not so easy not so easy to sell a huge project then you start to to do merch with different play ERS and to create different way of operating different way of special purpose vehicle different kind of society to continue with a project so first we do an internal risk assessment of that specific transactions yes for example it's going to be a joint venture a merch and acquisition and so on yes so first it's just the concept of the transactions and we identified that risk and we also consider the country where we are operating and also all the legal regulations where we have some basic ones that goes hands to hands with the extra extra territoriality law yes that will is transversal to the company but we add also the local law and then we start with the issue that not we as a compliance officer always have fun that is the basic anti-corruption checklist which is internal where we use open data that means free open data and when we need something extra we need softwares for doing that and we start to do certain kind of connections with Commerce Chambers and so on in some countries that were really risk I got in touch with Basel Institute and so on yes we start to do our internal checklist on desk it's something that we do when we acquires and also when we enters into a new business relationship and also with into a new market yes a new country it just identified any issue that may affect the customer ability to fulfill with our Contra obligations such as Financial stability legal compliance and any systems and its phase of maturity and it's not only only for the company but also for the people that are in charge of that and to whom we are H working on interconnective yes and as who do it yes that is the second question usually should be the compliance officer but sometimes in certain countries we have like different hats in that area yes so it's transversal so we look for certain Department that can help we take a lot that we are not going to have even a conflict of interest during the internal process yes that is something that it is key then we ask our perspective business partner to collaborate with us we give them to fill them in their office and I know your partner because it's not always client yes where we have to different way to to know how to ask and we really take care about confidential and private information so we divide it in reference with the level of relationship that we're are going to go on of course when we are under a merge and acquisition or a joint venture we have a template with plenty of questions yes and another one less demanding when we go with a regular compliance um screen yes that is something that the business partners provide to us and then we cross checked with our internal anti-corruption checklist and the one that came from outside yes and then that is something really which I really like it we start to interact with that company yes usually I used to have a call with them just I ask yes and sometimes I do it directly sometimes the the business development team the one that is in connection with those transaction ask them for them code of conduct compliance issues even though we have already check it if it is priv public or not and then we start to see if there is a a a gap yes in case there is a gap we get in contact with them to try to fulfill as much as possible with our requirements it's not only to sign it it's just we try to do as much as possible a due diligence a random due diligence yes to check if effectively they're working at the way we expect for that we have another special instrument that is called compliance rule for third party that will be like a code of code of conduct for third party where we reserve the right to do those kind of audits random audits out our own discretion and to see if something is not going by the way we were were were planning yes in term of compliance we have the right yes just to conclude with the contract yes and then if we detect a gap we start with a sensible process it's not like training because you we don't feel that we have to train anyone it's like everyone's warn being ethics no one wake up saying today I will I will corrupt yes it's just try to facilitate an instance where we share our principles basic what we understand as a corruption that is basic because for example world rank see it more like in the public sector and we go for the one yes for the that goes with International transparency and from shex from the Sherman the cooperation frame from shman government we adopt it that said that is every anything that means an abuse of power for private benefits yes so we go for a more wide perspective going back when when I was in the introduction sharing that we work really hard to try to create Collective actions even going out of our specific industry since 2018 I am collaborating with the alliance for integrity from CHS set from the international cooperation from chman government just giving training from Enterprise to Enterprise in Spanish we saide the Paras and also with passaport integ Integrity passport where we evaluate yes how a company especially as esms a small and Medi Enterprise develop their own project and then we evaluate them because we are really convinced that we cannot be doing business in an country where that is not a common way of working I will tell you something that was really challenging we have l two countries due to that because we were waiting waiting to start operating even though we were with offices there but in a moment we said it's impossible if you really want to interact with the government we have it's impossible to comply we wait we wait and said okay no way we left so it's not easy and we are in some risky countries but we understand that we really need to interact with our H Supply change doing facilitations Cafe Integrity Cafe tea Integrity Cafe mate here in Rio PL because we drink M but Con in connection with them and always in a friendly way yes the trainings are to be something friendly like a storytelling just talking about some news that we have saw in in the war yes and always thinking in shumar do you remember the F thank you Fernand sorry I'm so sorry I really apologize um I've just noticed we're really running out of time at the moment sorry and I really I really apologize for cutting you short but uh yeah I'm just uh cognizant that you know um it's really late at some places and I'm just thinking maybe um we can probably just uh proceed with the next session and I'm really I'm really sorry to cut you off but I'm sure your insights have been been been no no no no problem no problem I'm sure your insights have really been um well acknowledged there's a couple of very interesting questions and based on this as well and of course this shall um we shall continue with this also in the in the next um uh webinar sessions and I'm sure from our resources as well from UNC and unodc um we can get also a couple of U responses from what the audience is asking so once again thank you so much Fernanda and and yeah I apologize for for the short time it seems time is just moving now so thank you so much