Bribery & corruption

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Does your business have policies or practices to prevent corrupt and dishonest behaviour?

EXCELLENT Answers

No EXCELLENT answers have been published for this question.

GOOD Answers

No GOOD answers have been published for this question.

OKAY Answers

No OKAY answers have been published for this question.

POOR Answers

No POOR answers have been published for this question.

This Scorecard is due to be updated in 2018

In the words of the UK government: “Bribery and corruption create a disincentive to trade as well as uneven trading conditions that can damage economic systems and the individuals within them.”

In a global economy, all business is obliged to pay regular levies, duties and taxes to governments: these are the normal costs of doing business. But some companies also make irregular payments, which end up in private hands instead of providing public goods and services. This is a particular problem in countries where citizens struggle to hold their governments and public officials accountable. Some of these payments and donations may not be illegal, but can still offer an unfair advantage to companies that pay over those who cannot, or will not. For example, 'facilitation payments', which are payments made to low-level officials in overseas trade in order to speed up or obtain routine administrative processes, are illegal under U.K. jurisdiction but legal in the U.S.A.

Corruption may be as simple as paying money to obtain preferential treatment in a procurement process. It may occur through excessive and/or inappropriate payments or donations, for example, made to political parties in the clear expectation that this will confer unfair benefit on the donor. It may involve payment for insider information, such as a bid price. It may be more subtle and insidious, e.g. offering a job or access to a university place to an immediate family member of a person in authority.

The problem therefore is not limited to the bribing of personnel in government and the public sector but equally applies to corrupt behaviour between private entities or individuals. The 2010 UK Bribery Act introduced a corporate offence of failure to prevent bribery by persons working on behalf of a business. Companies can take steps to reduce risk, and protect themselves, by demonstrating that they have adequate procedures in place to prevent bribery.

There are many steps that a company may take to prevent corrupt and dishonest behaviour. These include, e.g. establishing an organisational culture in which such behaviour is understood to be unacceptable, distributing and disseminating internal guidelines against corrupt behaviour, reviewing whistleblowing procedures to ensure that internal wrongdoing can be reported and dealt with effectively, providing contractor guidelines to ensure suppliers understand company policies and expectations, and/or due diligence to ensure suppliers are also taking steps to prevent dishonest behaviour. Public disclosure and reporting of financial transactions may also help build trust and business reputation.

A framework of anti-corruption policies will vary according to business sector and circumstances but may include:
● Clear articulation of the company’s stance on bribery
● Details of procedures to be followed during business transactions
● A prohibition on offering, giving or accepting bribes
● Guidelines on offering and accepting gifts, hospitality or expenses by employees, or other parties that could influence the outcome of a business transaction
● A clear explanation of circumstances that could be considered a 'conflict of interest' for company employees or suppliers
● Guidelines on donating to special interest groups, whose activities may include lobbying
● Public disclosure of donations and payments the company, or its intermediaries, have made to political parties and charities.

Corruption

'Corruption' is the abuse of entrusted power for private gain. It damages everyone whose life, livelihood or happiness depends on the integrity of people in a position of authority. Undue influence occurs through excessive and/or inappropriate payments or donations to public officials, or exploitation of privileged access to them, in order to obtain certain benefits. Some of these practices may comply with the letter of the law but remain contrary to the spirit of the law.

Answering YES

All Businesses MUST

State their business sector; and where corruption can impact that sector

Describe their practices and policies to prevent corrupt and dishonest behaviour

All Businesses MAY

Provide a hyperlink to a published document

Provide evidence of the success of the policy

Answering NO

All Businesses MUST

Explain why they do not or cannot answer YES to this question, listing the business reasons, any mitigating circumstances or other reasons that apply

All Businesses MAY

Provide other relevant information

Mention any future intentions regarding this issue

DON'T KNOW is not a permissible answer to this question

NOT APPLICABLE is not a permissible answer to this question

Version 1

To receive a score of 'Excellent'

Corruption and dishonest behaviour the antithesis of the business ethos

Examples of policies and practices which may support an EXCELLENT statement (not all must be observed, enough should be evidenced to give comfort that the statement is the best of the four for the business being scored):

  1. An organisational culture in which corrupt and dishonest behaviour is absolutely unacceptable
  2. Robust practices and policies disseminated and implemented across the business
  3. Employee engagement facilitated and encouraged at every level of the organisation, such as a whistleblowing policy
  4. Well established training against corrupt and dishonest behaviour throughout the organisation
  5. Contractor/supplier guidelines to ensure they understand company policies and expectations
  6. Public disclosure and reporting of financial transactions
To receive a score of 'Good'

An established and robust approach to deal with corrupt and dishonest behaviour

Examples of policies and practices which may support a GOOD statement (not all must be observed, enough should be evidenced to give comfort that the statement is the best of the four for the business being scored):

  1. Robust practices and policies, addressing possible corrupt behaviour within its business sector, disseminated across the business
  2. Well established training against corrupt and dishonest behaviour for employees and management
  3. Contractor guidelines to ensure suppliers understand company policies and expectations
  4. Public disclosure of anti-corruption policies
To receive a score of 'Okay'

Approach to corrupt and dishonest behaviour is ad hoc

Examples of policies and practices which may support an OKAY statement (not all must be observed, enough should be evidenced to give comfort that the statement is the best of the four for the business being scored):

  1. Steps to prevent corruption or dishonest behaviour evident, but ad hoc rather than strategic
  2. Some evidence of employee engagement, such as employee guidelines, conflict of interest
  3. Due diligence to ensure suppliers are taking steps to prevent dishonest behaviour
  4. Understands the potential and/or risk of corrupt and dishonest behaviour within the business sector
To receive a score of 'Poor'

The business acknowledges performance below expectations or no action evident

Examples of policies and practices which may support a POOR statement (not all must be observed, enough should be evidenced to give comfort that the statement is the best of the four for the business being scored):

  1. Statement of future intent to improve
  2. No evidence of practices or policies to prevent corruption or dishonesty
  3. No understanding of risk of corruption in the business sector