We have a vacancy for a Full-Time Manager at our Paris office. Click the link to find out more.

We have a vacancy for a Full-Time Manager at our Paris office. Click the link to find out more.

Update Winter 2013

Season's Greetings from GoodCorporation

winter deerIt has been another busy year, for which we are grateful. We have conducted over 40 assessments in 21 countries on six continents and our business is continuing to grow. Consequently, we are recruiting further senior support to lead some of our assessment projects.
Much of this work has been in the area of anti-corruption compliance, which continues to be a focus for many companies. We are seeing many new initiatives in this area, some of which we share below.

From all of us at GoodCorporation, have a happy, successful and prosperous 2014.

GoodCorporation joins BSI Consultancy Programme to support BS10500 

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GoodCorporation is delighted to announce that it has been invited by BSI to join its Associate Consultancy Programme as one of only two consultants so far working with BSI on the BS10500 anti-corruption standard.

GoodCorporation was appointed on the strength of its expertise in assessing and developing anti-corruption programmes. Much of this work is based on the GoodCorporation Framework on Bribery and Corruption which was felt by BSI to map closely with BS10500.

International Anti-Corruption Day - is collective action the way forward?

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Corruption remains a significant obstacle to economic and social development. According to the World Bank, every year $1 trillion is paid in bribes, while an estimated $2.6 trillion is stolen annually through corruption – a sum equivalent to more than five per cent of global GDP.

While the UN urges governments and businesses to take action, we are seeing an increasing amount of anti-corruption activity in the corporate world.

At our Business Ethics Debates we hear a lot about the difficulties of putting some of this into practice in some of the world’s more ethically challenging locations. What has been interesting to note this year is the development of collective action in several of the countries where we have conducted assessments.

In Senegal, Tanzania, Egypt and Kenya we have seen groups of businesses collaborating to develop effective solutions that support a zero tolerance towards corruption. We support these initiatives and encourage businesses to spread this best practice in other areas of their operation.

The Banknote Ethics Initiative (BnEI), for which we have developed the industry scheme, is a good example of how an industry can work together to reduce corruption. Similar collective initiatives are to be supported and we are keen to share our expertise with other sectors thinking along these lines.

Business Ethics Debates: Prosecution and enforcement of the UK Bribery Act

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We were delighted that David Green CBQC, Director of the Serious Fraud Office (SFO), was able to lead our Autumn Business Ethics Debate on the UK Bribery Act. The debate focused on prosecution and enforcement and started with a reminder of the starting point for any action. The SFO will always apply the Full Code Test for Crown Prosecutors before any proceedings commence, ensuring that there is sufficient evidence to prosecute and that prosecution is in the public interest.

The debate looked at the moral imperative for reporting and the case for risk management. However, many were concerned that negative publicity, reputational damage, impact on share price and the ensuing process would deter such action.

Others, however, agreed with David Green that there is a moral case for self reporting and that it is indeed a risk-management exercise; better to be transparent and come forward rather than hide and be found out.

Adequate procedures were also discussed in detail and again the room was divided. Some felt that it still wasn’t clear what adequate procedures were and that even their advisers were unsure. Others stated that good professional advisers made the situation very clear and gave practical advice.

Read the full debate summary here.

In Brief...

GoodCorporation continues to build its global expertise

GoodCorporation continues to strengthen its international expertise. From Tanzania to Trinidad and Melbourne to Mexico, in the last three months we have worked in 11 countries on five continents.

This scale of international work gives us a unique perspective on how attitudes towards business ethics vary across the globe. Having an in depth understanding of this can be vitally important for businesses moving into new markets. Particularly those in challenging sectors such as extractives or defence.

We have a network of international consultants, experienced in different markets and sectors and can help businesses run, manage and measure how effectively their global compliance is working.

Details of our compliance support services can be found on our website.

What is Adequate?

GoodCorporation is preparing a white paper on anti-corruption compliance looking at best and worst practices and where businesses are  most vulnerable under current legislation.

Due to be published in the New Year, the report will show where companies are succeeding and where they are struggling to put adequate procedures in place.

The practicalities of managing corruption risks in the extractives industry

GoodCorporation asked Robert Welch from Kazakhmys to lead our November Business Ethics Debate on this challenging subject.

Fraud and corruption have long been problems in this sector. It is labour intensive, involves high-value commodities, is often based in remote parts of the world where there is inherent corruption and involves close links with government officials.

Identifying and managing these risks is essential if fines and reputational damage are to be avoided. However, developing the blueprint is far easier than the implementation.

The discussion focused on the five biggest challenges:

  • Facilitation Payments
  • Due Diligence
  • Community Projects
  • Procurement
  • Licences and Permits

The debate highlighted the risks posed by each of these challenges. Experiences and best practice were shared.

Read the full debate summary

The business of human rights

In November, we were invited by the Shift Project to join a panel of experts to discuss the implementation of the UN Guiding Principles on Business and Human Rights. The focus of the consultation was the development of public standards for reporting against the Guiding Principles.GoodCorporation introduced the session on internal audit and assurance, highlighting the need for qualitative and quantitative reporting based on consultation with all stakeholder groups. This should include governments, international agencies, NGOs and Civil Society Organisations.GoodCorporation has been working on human rights focused assessments for a number of years. Much of this uses our Human Rights Framework designed to measure the management practices in place that demonstrate a responsible approach to respecting human rights.

Update Autumn 2013

GoodCorporation launches Compliance Support Programme

Autumn sees the launch of GoodCorporation’s Compliance Support Programme designed to assist companies as they embed robust anti-corruption procedures throughout their organisations, particularly in emerging markets.

We know that in some sectors, companies are struggling to get effective compliance programmes up and running, particularly when entering a new country. Therefore we have developed a range of support services to help businesses do this.

Included is the provision of Interim Compliance Managers – people with compliance expertise who are on the ground to help our clients design and deliver a local compliance programme. We have a global network of associates that respond appropriately to local needs, especially in high-risk emerging markets.

We have helped clients with the development and deployment of anti-bribery management systems including policy formation, due diligence, contractor training and whistleblowing handling.

We would be delighted to hear from anyone wishing to learn more about these services. Please contact us.

Also in this edition of Update we comment on recent government initiatives, share examples of best practice and give details of the conferences where we will be speaking.

Michael Littlechild

Managing corruption in India

India is one of the most popular countries for foreign investment.It offers businesses low labour costs, a stable political climate, an efficient financial system, excellent transport and good communications.

Yet it is dogged by corruption.Transparency International ranks it 94th out of 176 in its Global Perceptions Index. Public procurement, public utilities, tax and customs, the police and the judiciary are all known to be susceptible to bribery. Even cricket is mired by allegations of match fixing.

Demands for bribes are commonplace in both the domestic and corporate arenas. In the business world, the recent multi-billion dollar scandals such as the mis-selling of telecoms licences and the alleged corrupt purchasing of defence equipment showed that corporate corruption has reached epic proportions.

Indeed, such high-profile scandals have made corruption worse further down the chain, with officials assuming they can ask for smaller demands if those higher up the pecking order are getting away with larger scams.

Against this background is the emergence of a large-scale movement of public outrage that is forcing the government to act. It may be a slow process, but there are steps that companies can take to avoid paying bribes and ensure that their businesses comply with international legislation.

Click here to read the article in full.

 

GoodCorporation leads the debate on anti-corruption and ethical culture

GoodCorporation is speaking at a number of conferences this Autumn on ethical corporate culture and anti-corruption.

Adequate procedures and combating corruption remain high on the corporate agenda. The Serious Fraud Office is making its position clear on enforcement and prosecutions are said to be imminent.

However, increasingly businesses recognise that the issue goes beyond prosecution. Any accusation of corrupt behaviour is immensely costly in terms of management time and reputation. What we are seeing in response to this is a growing focus on ethical corporate culture.

When we spoke on corporate behaviour, ethics and culture at the annual conference of the Chartered Institute of Internal Auditors in September, there was a ten-fold increase in the number of delegates attending this particular workshop. As compliance departments work hard to implement robust anti-corruption policies to demonstrate adequate procedures, they can see how a properly embedded culture of ethical conduct can be the bedrock of their activity. As the tick-box approach of too many sectors has shown, simply complying with the rules is no guarantee of good behaviour.

We will be debating these issues as well as adequate procedures, anti-corruption due diligence and managing third party suppliers at the Third Party and Counter Party Relationships Risk event on Paris on October 10 and at Compliance Week Europe in Brussels on October 14-15.

In Brief...

GoodCorporation's expertise in global anti-corruption compliance continues to grow

Since the start of the year, GoodCorporation has been asked to test ABC procedures in yet more of the word’s ethically challenging environments.

Countries where this work has been conducted include China, Kazakhstan, UAE, South Africa, Senegal, Egypt, and Tanzania.

We have now conducted ABC assessments in 15 countries.  Managing corruption in India (left) is the latest in our series of articles designed to share the knowledge we have learned in order to promote best practice.

How far should companies go to combat corruption?

Leo Martin will be leading a debate on combating
corruption when he hosts the keynote session on day one of the Compliance Week Europe conference in Brussels on October 14. The discussion format is based on the highly popular GoodCorporation Business Ethics Debates.

Panelists will explore how much companies should do, and can do, to combat corruption.

 

The business of human rights

The UK has become the first country to develop an action plan on business and human rights, following the publication two years ago by the United Nations of John Ruggie’s Guiding Principles on Business and Human Rights.

This is a welcome move from the UK. Ruggie’s Guiding Principles added clarity for companies as to the respective roles of state and business in protecting and respecting human rights.

As William Hague said; “Doing business with respect for human rights matters. It’s good for people, for prosperity and the UK”.

Businesses can test whether they comply with UK guidance by assessing their procedures against the GoodCorporation Human Rights Framework.

Contact us for information

It matters where you shine the light

If the Prime Minister is serious about creating “the most open and transparent government in the world” then the Lobbying Bill should cover the whole of the UK’s £2bn lobbying industry, not just the one per cent included in the draft legislation.

Unless the government is prepared to shine a light on the whole of the industry it will be a wasted opportunity, preserving the status quo and paving the way for more scandal and reputational damage.

See the goodblog

Update Summer 2013

GoodCorporation to host business ethics debate at Compliance Week Europe event

The need for effective global compliance and governance has never been more pronounced. Failing to get these vital areas of management right can have lasting and damaging consequences for international corporations.

From our Business Ethics Debates we know how much of a challenge it can be for multinationals to embed the necessary policies and codes of conduct successfully. This year we are taking our popular Business Ethics Debate format and are co-hosting a discussion on effective anti-corruption compliance at the first Compliance Week conference to be held in Europe.

GoodCorporation’s Leo Martin and Compliance Week editor, Matt Kelly, are leading a panel discussion that will pose the question – “How far should corporations go to combat corruption?” We will be joined by an impressive panel including Gemma Aiolfi  Head of Corporate Governance and Compliance at the Basel Institute on Governance, and Tamara Northcote, Head of ABC at Vodafone.

Compliance Week Europe is being held at the Hotel Sofitel in Brussels from 14-15 October 2013. The debate will be held as the keynote session that closes day one of the conference. The conference will be attended by compliance, risk and audit executives from corporations across Europe, Africa and the Middle East.

GoodCorporation clients and readers of Update are entitled to a €200 discount using the code GoodCorp200. The early-bird rate, available until July 31, is €800.

For more information about the conference or the debate, please contact Sally McGeachie.

GoodCorporation develops framework for Banknote Ethics Initiative

GoodCorporation has developed the auditing framework for the Banknote Ethics Initiative (BnEI) which was launched in May to promote ethical business practices within the banknote industry.
The initiative was set up by a number of leading organisations in the banknote industry, including De La Rue, Crane Currency, Arjowiggins Security, SICPA, KBA NotaSys and Giesecke & Devrient.

Maintaining high ethical standards across the banknote industry is essential if customers and other stakeholders are to be totally confident that business practices are beyond reproach at all times.

BnEI members will be required to adhere to a strict Code of Ethical practice that was developed by the Institute of Business Ethics.

GoodCorporation has translated this code into the BnEI audit framework. The framework sets out a list of good practices that all BnEI member should adopt to ensure the robustness of their management practices in relation to the risks of bribery, corruption and breaches of anti-trust legislation.

Four of the founding companies are working with GoodCorporation to evaluate themselves against the BnEI framework.

Are business ethics getting worse?

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Our latest business ethics debate, led by Will Hutton, examined the topic ‘Are business ethics getting worse? It was suggested that business ethics had reached its nadir in the mid-noughties, but was now starting to improve.

Looking back at the origins of the company, it was argued that the role and responsibilities of corporations have changed. When companies were first incorporated in the 16th century, they were required, by law, to have a declaration of purpose. Built into this declaration were the company’s obligations to society, which, it was suggested, helped to ensure that businesses promoted and abided by good business ethics.

Our debate examined how and why the rules changed and looked at the historical and economic factors that had an impact on corporate behaviour. The room was almost equally divided between those who felt that ethics were the same as they had always been and those who felt that there were now real signs of improvement.

To read the debate in full, click here

 

In Brief...

Vodafone working with GoodCorporation to evaluate ABC systems

As one of the world’s leading mobile phone companies, Vodafone has established compliance controls in place.

As part of reviewing these procedures, in accordance with the adequate procedures guidance under the UK bribery Act, Vodafone has been working with GoodCorporation to evaluate its systems and to benchmark them against other global companies.

Are CR Reports worth it?

CR reports drop into GoodCorporation in-boxes on a daily basis, more often than not, making what they consider to be significant claims about responsible behaviour.

What is most worrying about these claims, is the damage they do to the a proper understanding of what responsible business behaviour really entails.

More often than not, the claims are unrelated to the company’s core activities – what it makes or does and for whom. They say little, if anything about the ethical, environmental and social impacts of the company’s business activities.

As GoodCorporation has argued for over a decade, CR reports will only be taken seriously when they measure what really makes a business responsible: how it sells, how it buys, how it treats its employees, the community and its shareholders.

CR reports have sadly become totally separated from these core issues. Given the crisis of trust in business, it is time to ditch this type of meaningless assessment and move onto a more serious and independent measurement of the real ethical and social impact of business.

Curbing executive pay

Many of the reforms to curb excessive executive pay, announced last month by business minister Jo Swinson, were a step forward.

Facilitating the comparison between company performance and executive pay could help bring about an end to the culture of payments for failure. However, there are limitations as to how effective this legislation can be on its own.

The proliferation of short-term shareholdings means that it is increasingly unlikely that shareholders are actually in a position to hold the executive to account.

The other missed opportunity is that this initiative only covers executive pay and does not look at pay structures as a whole. Extreme divergences in pay, an over-reliance on commissions and short term sales targets have had a corrosive impact on ethical behaviour.

Forward-thinking businesses are starting to put such structures under review, thinking more widely about pay, performance and the development of a healthy business culture.

News and Views

For the latest GoodCorporation views on ethics and responsible practice you can visit our website or read our thoughts on the goodblog. We are also on twitter.

Update Spring 2013

Welcome to the Spring issue of Update.

We are delighted to announce that 2012 was a record year for GoodCorporation and are confident of building on that success in 2013. Our responsible business assessments and associated services are continuing to grow, but above all we are seeing interest in and demand for our Anti Bribery and Corruption (ABC) programmes.

We have an increasing number of listed clients, including 17 in the FTSE100 and six in the CAC40. To date, we have completed over 400 assessments in 50 countries, ensuring that our understanding of responsible and ethical business practices is truly global.

We explore that in this issue by taking a look at bribery risks in China; the first in a planned series of articles that will examine some of the real issues companies face in the more ethically challenging parts of the world

If anything strikes a chord, we’d be delighted to hear from youome of the current thinking and best practice in ethical business management and compliance.

Michael Littlechild

Corruption in China - the challenges and the tools to tackle it

Under the leadership of President Xi Jinping, corruption has become a hot political topic in China. His rousing speeches, vowing to tackle the problem of corrupt officials at both a high and low level, have pushed corruption higher up the corporate agenda. Prior to assuming power, he was known for his zero-tolerance towards corrupt officials. Now President, many feel sure he will deliver more results than his predecessors, others are conscious that implementation takes time and are watching the reaction of different government entities closely.

Rhetoric aside, corruption remains a key consideration for all foreign companies doing business in China, with cultural differences playing a vital role in understanding and tackling the problem.

Click here to read the article in full.

GoodCorporation's Business Ethics Debate Series

Over 100 leading organisations have attended our Business Ethics Debate series over the past 12 months, including Arcelor Mittal, Astra Zeneca, BAE Systems, BP, Diageo, Exxon Mobil, Shell, Vodafone and Total.

Each event is attended by up to 30 business leaders, industry experts, politicians and academics who join us to debate challenging aspects of business ethics. Recent topics have included Anti-Corruption Due Diligence, Ethical Challenges in the Defence Sector, The Bribery Act 12 Months On and The Rise of Business Ethics.

Hosted at venues such as the House of Lords or the Club France-Amérique in Paris, our debates provide a forum where industry leaders and opinion formers can share best practice as well as highlighting the key ethical issues their industry faces. The Chatham House Rule is always applied to enable a frank and honest exchange of views.

Although attendance is by invitation only, summaries of our debates are posted on our website and often reproduced here in Update.

Andrew Hayward, Head of Compliance at Balfour Beatty described them as “Definitely one of the most valuable events I go to”. David Halford, Head of Ethical Sourcing at BBC Worldwide said, “GoodCorporation’s Business Ethics Debates bring together a diverse range of experts for a tightly-facilitated discussion on some important topics.”

Click to read the summary of our debate on Anti-Corruption Due Diligence

Ethics in the Food Chain

Ethical business conduct, has once again played a central role in some of the news stories that have dominated the headlines in the first quarter of 2013, most notably ‘Burgergate’.

Prior to the discovery of horsemeat in frozen burgers and other processed beef products, the majority of testing was on fresh meat products following  the outbreak of BSE.  To date, retail supply chain monitoring has tended to focus on child labour and factory conditions, with the emphasis most firmly on the manufacture of clothes and electrical goods rather than the processing of meat.

Instead, supermarkets and food producers have concentrated their efforts on promoting an idea of wholesomeness and taste, while failing to check what they were actually selling. Consequently when Irish food inspectors found horsemeat in frozen beef burgers, many of the supermarkets concerned were caught on the hop, initially  hoping it was an isolated incident that would quickly go away. It didn’t.

To date, mislabeled food products have so far been discovered in the UK, the Republic of Ireland, France, Norway, Austria, Switzerland, Sweden, Spain, Italy the Czech Republic and Germany. Suspicious products have also been withdrawn in the Netherlands as tests are carried out.

Meanwhile answers to the question ‘why?’ are still being sought. Some have blamed the excessive complexity of the food industry’s supply chain, with the meat for many products moving through several countries before ending up as lasagne on supermarket shelves.

Others have blamed consumer demand for cheap meat. This is unacceptable; retailers cannot blame their customers for not buying a more expensive product when a cheap one goes wrong. Many have put it down to simple fraud for financial gain; horsemeat being cheaper than other meats in some European countries.

The real issue, however, is a lack of responsibility and proper controls.  In the UK, manufacturers and retailers have been happy to delegate their responsibility for food safety and hygiene to the Food Standards Agency. But the agency’s checks do not take account of authenticity. The FSA’s brief is to identify ‘those risks that can make people ill or worse’, such as arsenic or listeria. So despite checking 80,000 food samples in 2012, they were not testing meat DNA.

Until now, the meat processing chain has been below the radar, but now the industry needs to work hard to catch up. What industries must acknowledge, is that arguing for less regulation and fewer rules means that companies need to take more responsibility for what they make and sell, not less. This means thorough due diligence checks on the supply chain, regular monitoring and an in-depth knowledge of everyone you do business with.  Many companies are stepping up their due diligence in order to comply with the UK Bribery Act, but as we can see from the horsemeat saga a lot of reputational damage can be avoided if you know exactly what it is you’re selling.

In Brief...

GoodCorporation works with Ford Retail to ensure high standards of corporate behaviour

Ford Retail, a new GoodCorporation client, has set up a work stream at board level to ensure high standards of corporate behaviour are maintained throughout the business, covering staff, customers, suppliers, the community, the environment, management and other key stakeholders. In order to assess where they are, GoodCorporation has conducted a high level review against the key headings of the GoodCorporation Standard. The results will help focus initiatives over the next couple of years with a view to achieving the GoodCorporation Standard.

GoodCorporation work quoted in House of Lords Baroness Parminter praised the work of GoodCorporation in a recent debate at the House of Lords as part of the All Party Group on Ethical and Sustainable Fashion.

Arguing that not enough is being done to improve labour standards in the supply chain, Baroness Parminter highlighted the failure of supply chain audits to detect the real problems, relying too heavily on bribable inspectors.

Highlighting the work of GoodCorporation client BBC Worldwide, Baroness Parminter praised its refusal to rely on third party certification and its policy of making unnanounced checks on suppliers.

GoodCorporation was commended for bringing the debate to the fore and pushing managers to take greater responsibility for standards.

GoodCorporation strengthens Ethics Course for Imperial

GoodCorporation has updated the modules on the Ethics and Professional Standards Course that it developed for Imperial College Business School in 2011.

Part of Imperial’s MSc in Finance and its MSc in Risk Management and Engineering, the revised modules cover Libor, Insider Trading and SRI funds. Designed to give students a thorough understanding of ethical practices in the financial sector, the online courses offer practical guidance that will apply to students’ work post graduation.

Corporates against Corruption

When Transparency International published its Corruption Perceptions Index at the end of 2012, it revealed that two thirds of the countries and territories it ranked had scores that would indicate serious corruption problems in their public sector.

What concerned Transparency the most, was how little countries had done to reduce corruption given the recent global focus on bribery.

This appears to be in direct contrast to the efforts of the business community. Since the Bribery Bill made its first appearance in the Queen’s speech in 2009, corruption and how to stoop it has risen up the corporate agenda.

From the work that we do and the Business Ethics Debates we have held on the subject, GoodCorporation has a detailed perspective on the full scope of work that businesses are undertaking to tackle corruption and the challenges this presents.

Our article in the February edition of Ethical Performance looks at Corporates against Corruption: the development of effective ethics-driven anti-corruption compliance departments; high-level anti-corruption reviews; risk assessments and the implementation of a successful ABC process.

We acknowledge the difficulties businesses face in combating corruption, particularly within large global organisations, calling on governments to do more than simply legislate and prosecute to help businesses in their fight.

Click here to read the article

GoodCorporation helps global EPCM company review code of conduct

GoodCorporation has also been working with a global Engineering, Procurement, Construction and Management Group, to review its revised Code of Conduct with particular emphasis on the areas covering anti-bribery and corruption (and with specific reference to the UK Bribery Act).

GoodCorporation provided a short report outlining a number of recommendations and provided a benchmark table assessing the code versus that in other leading businesses.

News and Views

For the latest GoodCorporation views on ethics and responsible practice you can read our thoughts on the goodblog. We are also on twitter.

Update Autumn 2012

Compliance is no panacea.

While politicians and commentators have been calling for greater corporate responsibility to restore trust and boost economic growth, many leading businesses have been taking action and have been looking at increased compliance.

Although some high-risk or highly regulated industries have well-established compliance departments, for a significant number this is a new function. This move is being driven by several factors, the most influential being the Bribery Act, with its tougher corporate offence of failing to prevent corruption.

Of the 18 new companies we have been asked to work for since January 2012, all FTSE 100/250 or equivalent, the vast majority are working on compliance issues, be it measuring adequate procedures, benchmarking anti-corruption practice, developing effective compliance programmes or managing human rights or anti-trust issues. GoodCorporation is advising these organisations on implementing values-based rather than tick-box compliance to embed a culture of good behaviour that will minimise risk and protect reputation.  As our Business Ethics debates are showing, values-based compliance is is increasingly being regarded as best practice.

This edition of Update looks at some of the current thinking and best practice in ethical business management and compliance.

Michael Littlechild

Do business ethics add value or cost?

GoodCorporation’s second Business Ethics Debate in Paris looked at whether or not business ethics and compliance functions can be said to add value to an organisation, or are they simply additional costs.

The debate explored the role of ethics and compliance from a number of angles; as a necessary measure for protecting reputation; as part of a company’s marketing strategy; a means of creating a virtuous circle to improve a business as a whole or simply the right way to do business.

Many felt that we are seeing a tangible shift in favour of ethics and compliance as the central part of a strategy to restore trust and protect reputation.

GoodCorporation is seeing an increasingly important role for the ethics and compliance function in screening and monitoring the activities of suppliers and other third parties. Many more companies are starting to evaluate suppliers seriously in terms of anti-corruption policies, human rights, labour standards and environmental performance.

We also see the best ethics and compliance functions adding to a ‘virtuous circle’ in their organisations. This circle is based on a simple logic that as stakeholders are treated well, this treatment is returned in terms of loyalty, recommendation and ‘licence to operate’.

Conversely, those companies that rely heavily on a compliance function that follows the letter rather than the spirit of the law and ignore wider ethical issues, often struggle to create good cultures. Instead they can create an environment in which no one feels responsible for protecting the organisation’s reputation.

A full summary of the debate can be read on the goodblog.

GoodCorporation welcomes Transparency International Corruption Study

While defence budgets are coming under intense scrutiny in Western Europe and North America, the pressure is increasing on defence companies to sell into higher risk markets with weaker anti-corruption controls. So Transparency International’s Defence Companies Anti-Corruption Index, which showed that two thirds of the world’s largest defence companies do not provide enough evidence of the steps they take to combat corruption, is of real concern.

Mark Pymen, head of defence at TI and the lead author of the study, is right to say that the degree to which a company is willing to publish details of its anti-corruption safeguards is directly linked to the effectiveness of its anti-corruption effort.

However, this is only step one. What is especially worrying about this report, particularly in a sector that has repeatedly and regularly faced charges of corruption, is that developing and publishing anti-corruption safeguards and policies is the easy bit.

The real test of a robust anti-bribery and corruption (ABC) programme is the effectiveness of its implementation.

From the work we do, including assessments in the defence sector, we know that there is often a gap between policy and actual practice. In addition to developing anti-bribery practices and communicating a zero tolerance towards corruption, companies need to carry out regular checks to see how their ABC programme is actually working on the ground.

Transparency International’s defence company study is therefore a welcome initiative that could have a significant impact on raising ethical standards in this sector. We hope to see it embraced by the sector as a whole, with companies seeking to improve their grading year on year.

Click here to read our full report on the TI study

In Brief...

Watching out for whistleblowers

Businesses striving to establish an ethical corporate culture are encouraged to set up an effective speak-up system. Working on what is now a clearly established truth that misconduct damages corporate reputations, a good whistleblowing system can act as a company’s eyes and ears, providing an early warning system so that real reputational damage can be averted.

But the whistleblowing stories that have hit the headlines in recent weeks would indicate that all is not as it should be.  We have seen stories of government regulators insulting whistleblowers and asking them never to contact them again. There have also been reports of routine dismissal, despite the fact that such individuals are protected by UK law.

In an ideal world, organisations should not need a whistle
to alert them to problems before any damage is done.

However, as more companies recognise that an effective speak-up system can be crucial to managing risk and protecting reputation, GoodCorporation is increasingly being asked to advise on how this can best be achieved.

Our guidance on how to get this right is now available on our website.

Logistics companies exposed under UK Bribery Act

This summer GoodCorporation conducted a survey of leading logistics and freight forwarding companies which revealed that twelve months after the Bribery Act was passed, a significant number have insufficient procedures in place to prevent corruption.
A third of the companies surveyed had no published anti-corruption policy or statement and more than half make no public statement at all regarding facilitation payments.
This flies in the face of Ministry of Justice Guidance on the Act, which states: “top level management commitment to bribery prevention is likely to include communication of the organisation’s anti-corruption stance”.

From the work that GoodCorporation carries out in this area, we know that a failure to publish an anti-corruption policy or statement is likely to indicate that little or nothing is being done to prevent bribery. The fact that the multi-billion dollar logistics industry has failed to take this first step is very worrying.

Logistics is one of the most exposed sectors to corrupt activities, with companies in this field often working in some of the world’s most ethically challenging environments.

The full report and resulting press coverage are available on our website.

News and Views

For the latest GoodCorporation views on ethics and responsible practice you can read our thoughts on the goodblog. We are also on twitter.

Update Summer 2012

Welcome to the Summer Issue of Update.

Welcome to the Summer Issue of Update.

Once again, the subject of business ethics has dominated the headlines. The Libor scandal and subsequent resignations of senior Barclays executives illustrate how damaging unethical conduct can be.

When Bob Diamond resigned, George Osborne described it as “the first step towards a culture of responsibility”. So what is the second? Our blog outlines the GoodCorporation view.

The Bribery Act has also had an impact on corporate behaviour. When it became law last summer, it represented the first major change to UK anti-corruption legislation in over a century. Since it came on to the statute books it has been the focus of much management attention as businesses endeavour to ensure that adequate procedures are in place to prevent corruption.

In addition to hosting debates which have allowed businesses to share best practice and outline the challenges compliance has presented, we have also conducted some research into anti-corruption practices in the logistics sector. A staggering one in three leading logistics companies has no published anti-corruption policy and more than half make no statement on facilitation payments.

So far, despite the law making it easier for prosecutors, there have been few investigations by the Serious Fraud Office over this period. However, although businesses will be waiting to see how the re-organised SFO will operate, fear of prosecution is not the only driver here.

From our business ethics debates and the work that we have been doing with companies, we know that increasingly, operating an effective anti-corruption system has more to do with winning work, particularly from large corporates or the public sector, than staying out of jail.

This issue of Update takes a look at what businesses have been saying at our debates about meeting the requirements of the new law.

Michael Littlechild

GoodCorporation discusses third party due diligence at Business Ethics Debate

Twelve months on, it is due diligence that is proving to be the most challenging aspect of complying with the UK Bribery Act.

Hard though this is proving to be, businesses cannot afford to put it in the ‘too difficult’ box. In 2011, every US Foreign Corrupt Practices Act/Securities and Exchange Commission investigation (FCPA/SEC) involved the payment of bribes to third parties.

GoodCorporation’s March Business Ethics Debate looked at the issues involved in implementing a sound due diligence process and the problems some companies are facing in order to ensure that their practices and procedures would be deemed adequate.

For many companies, the definition of good due diligence remains unclear, creating confusion as to the lengths a company should go to in order to check the businesses with which they work. While some companies called for shared due diligence across sectors or some form of certification to avoid repetitive checking, it was noted that any form of certification or checking is only as good as those that carry it out.  As businesses are responsible for the activities of companies acting on their behalf, it really is essential that any information provided is double checked, particularly in high-risk areas.

This doesn’t mean that a collaborative approach should always be avoided. In some parts of the world, companiesindividually, collectively or on a pan-industry basis, should be working with governments and embassies to effect a change in culture. Having put the Bribery Act on the statute book, the government should be empowering its embassies to help UK businesses abide by the legislation when operating abroad.

To develop a truly effective due diligence system, businesses need to be clear who is responsible for the process and ensure that it is really being driven from the top of the organisation. It is also essential to make sure that the system is properly embedded with an effective speak-up process in place to act as an ongoing monitoring device.

Finally regular checks should be conducted, not just to ensure that the systems are working but also to verify that. having passed the selection test, there is evidence that good behaviour is meeting expectations.

Read the full summary of the debate.

The Bribery Act Twelve Months On

GoodCorporation’s Business Ethics debate on The Bribery Act twelve Months On invited companies to share their experiences and the challenges they have faced implementing the Act

Not surprisingly perhaps, the key areas up for discussion were gifts and hospitality, due diligence and facilitation payments.

Gifts and Hospitality

Prior to July 2011, much of the media opposition to the Act focused on the fear that its introduction would herald the end of the UK’s hospitality industry. This has not proved to be the case, nor has its implementation been as challenging as people expected.

There has been no significant change to policies in the UK as many firms already had limits in place, although some companies now ask guests to confirm that accepting the invitation adheres to their own company policy. The only hospitality that was called into question was that at the Olympics, with its hefty price tag placing it in the ‘excessive’ box for some companies (see full story in ‘In Brief’).

Due Diligence

Almost all businesses are finding due diligence a real challenge, as we had heard at our debate in March. Some companies are performing checks on tens of thousands of suppliers, while others remain unsure how best to tackle this and have no system in place.

Risk assessment is undoubtedly the key, enabling businesses to conduct the appropriate checks on the right suppliers.

GoodCorporation urges companies to look closely at the activity of suppliers to identify the opportunities for corruption. Suppliers should then be categorised according to risk and checked using questionnaires, audits, or research as appropriate, signing agreements and conducting training as an additional safety net, where possible.

Facilitation Payments

Although facilitation payments have never been allowed under UK law, the biggest problem for businesses is working out whether or not someone is paying them on your behalf. While a ‘miscellaneous expense’ is an obvious alarm bell, they are usually hidden far more subtly, built into the fee structure which makes them hard to identify.

Ensuring that a company’s own employees deal directly with public officials can help, but the policy on ‘tips’ should be clearly communicated. Where possible, work with organisations with a stated policy not to make such payments. In many parts of the world however, this is easier said than done.

The majority of companies felt that appropriate plans were in place, but there was still some way to go to ensure that they were properly implemented. Our full summary of the debate covers other areas that were raised including training, speak up, major bids and dealing with problem suppliers.

In Brief...

Business ethics drives surplus in Olympic hospitality tickets

Businesses are more likely to turn down hospitality packages to the Olympics than to Lords or Twickenham, despite public demand far outstripping supply.

At our Business Ethics debate on The Bribery Act Twelve Months On, companies confirmed that although the Act had not led to any major change to their gifts and hospitality policies, the value of Olympic tickets exceeded the limit of a few hundred pounds, already set in many organisations. Consequently a number of companies confirmed that invitations to the Olympics were the most likely to be refused.

Commenting in The Telegraph,Michael Littlechild said; “In some companies, executives are required to ask permission before they can accept anything much more than a lunch. This is effectively a form of self-regulation, as employees don’t want to be seen asking to attend lavish or extravagant events.”

GoodCorporation continues ethical assessments for Total

To ensure compliance with its Code of Conduct, Total asks GoodCorporation to conduct ethics assessments of selected affiliates and business units each year.

We are now in our tenth year of working for Total and have completed assessments in over 50 countries including Yemen, Indonesia, Angola, China, the USA, Singapore, Russia, Cameroon, Mexico and France.

These assessments address a range of issues including business integrity, labour standards, the environment, anti-corruption and human rights. The results are then benchmarked and monitored to ensure standards are maintained.

GoodCorporation carries out worldwide review for bwin.party

PartyGaming, a long-standing GoodCorporation client, merged with bwin Interactive Entertainment on 31 March 2011 to create bwin.party digital entertainment, the world’s largest listed online gaming company.

The newly-formed bwin.party asked GoodCorporation to test its procedures worldwide against the GoodCorporation Standard, with added criteria on responsible gaming. The review came at a time when the online gaming industry was undergoing a significant and rapid shift with fully regulated markets opening up in major European countries, including France, Italy and Spain. New nationally-based regulatory and tax regimes continue to be introduced in Europe, providing the online gaming industry with the freedom to advertise and grow their services.

A key factor in winning licences from these new regulatory bodies is the ability to demonstrate that responsible and sustainable business practices are in place. GoodCorporation is promoting its assessments as an independent, credible measure of both responsible gaming controls and wider responsible business practices to the new regulatory bodies in Europe.

GoodCorporation develops Adequate Procedures Toolkit for BG Group

GoodCorporation worked with BG Group to help develop an ‘Adequate Procedures Toolkit’ that can be used by different parts of the business to verify the effectiveness of the company’s  anti-bribery procedures. We helped test the toolkit in Egypt and Norway and will be working with BG to use the toolkit more widely this year.

In addition, we were also asked to conduct a high-level review of BG Group’s policies and processes that were relevant to the Bribery Act. Our review showed that the company was better prepared than many of its peers, with many examples of best practice, it also made recommendations for improvements that BG was able to address.

GoodCorporation conducts further assessments for Degrémont

GoodCorporation has conducted two further business ethics assessments for Degrémont, a subsidiary of SUEZ ENVIRONNEMENT.

Degrémont is one of the latest companies to achieve GoodCorporation accreditation and these assessments in Brazil and Spain formed part of the company’s on-going programme to maintain GoodCorporation accredited status.

News and Views

For the latest GoodCorporation views on ethics and responsible practice you can read our thoughts on the goodblog. We are also on twitter.

Update Spring 2012

The Business of Human Rights.

The recent report from War on Want on abuses in factories producing Olympic branded sportswear, highlights not only the role businesses have in protecting human rights, but also the difficulties they face in trying to do so.

As we have seen with the Bribery Act, businesses are increasingly being held responsible not just for their own actions, but for those of their suppliers and other third parties acting on their behalf.

This places considerable importance, not just on having and issuing a code of conduct, but on checking that it covers all that it should and is being properly implemented on the ground.

Most global businesses do have a code of conduct and insist that its suppliers adhere to it. But without regular due diligence checks, they run the risk of exposure and reputational damage, as we have seen with repeated supply chain scandals. Global organisations need to feel reassured that their suppliers will behave in line with company expectations, even when no one is watching.

As global communication becomes easier and more far reaching, this element of risk mitigation will become ever more important.

Michael Littlechild

GoodCorporation launches Human Rights Framework

GoodCorporation has launched a Framework on Human Rights designed to help corporations demonstrate a responsible approach to protecting and respecting human rights throughout their organisation.

Introduced at the most recent GoodCorporation debate at the House of Lords the framework will enable businesses to measure and improve the robustness of their Human Rights policies and systems, providing a blueprint for Human Rights Due Diligence.

Following the methodology of the GoodCorporation Standard, the Human Rights Framework assesses 91 policies and procedures where human rights abuses are most likely to occur. Areas covered by the framework include Forced, Bonded and Child Labour, Discrimination, Workplace Health and Safety, Conditions of Employment Security and Supply Chain Management.

Commenting on the launch of the Framework, GoodCorporation’s Leo Martin said: “From the assessment work that we have conducted for global organisations, we know that due diligence in this area can prove particularly challenging. Our work with businesses has enabled us to develop a framework that will reduce the challenge and facilitate a proper assessment of their human rights position.”

International businesses benefit from GoodCorporation accreditation

FTSE and GDF SUEZ subsidiary Degrémont, the global water treatment specialists, are the latest companies to use their 2011 GoodCorporation accreditation to promote their business principles and code of ethics.

In FTSE’s recent report on the company’s commitment to the UN Global Compact, chief executive Mark Makepiece highlighted GoodCorporation’s audit of FTSE’s internal systems as the means by which the company measures performance against the principles of the UN Global Compact. Full details of GoodCorporation’s assessment are included in the report.

Degrémont features the GoodCorporation accreditation logo on the ethics page of its website to reinforce the company’s commitment to its international Ethics System. Degrémont was the first company in its sector to obtain GoodCorporation’s accreditation.

GoodCorporation defends Health and Safety Legislation

Choosing to repeal legislation that has led to an 80 per cent reduction in work place fatalities would seem an odd political choice.Yet this is what David Cameron has proposed in his bid to “kill off Britain’s health and safety culture for good”.

The UK is rather good at Health and Safety, with one of the lowest fatal injury rates in Europe. And contrary to the statement that Health and Safety is an “albatross hanging round the neck of British Business” that hampers growth, figures from the Health and Safety Executive (HSE) show that Health and Safety representatives save almost £600m per year based on the reduction in lost time from occupational injury and illness. This is calculated on the reduction of between 286,000 and 616,000 lost days per year.

While no one in business would support unnecessary bureaucracy, much of the hoohah surrounding Health and Safety is more fiction than fact.

Read More

In Brief...

GoodCorporation debate reveals lack of Human Rights Policies 

The latest GoodCorporation debate revealed that few organisations have a specific Human Rights Policy in place or a nominated individual responsible for monitoring their Human Rights impact.

In addition, only a handful of organisations admitted to conducting fact finding exercises to see what was happening on the ground or carrying out risk assessments to identify potential problems.

The debate was held in response to the publication last year, by the United Nations, of John Ruggie’s Guiding Principles on Business and Human Rights. This stated that businesses have a duty to respect human rights and provide a remedy should violations occur.

Businesses confirmed that the Ruggie report had provided meaningful guidance on how to monitor their human rights impact.

The debate analysed the difficulties businesses face in this area and the steps that can be taken to manage human rights issues within their organisation.

Read more

House of Lords debate: Ethics vs Compliance

Following on from the successful debate in Paris on Ethics versus Compliance, GoodCorporation concluded its debate series for 2011 with a discussion for UK businesses on the same theme.

Representatives were asked if they felt that their business was moving away from compliance and towards ethics or vice versa, with the majority indicating a move towards ethics.

It was suggested that many organisations had focused on compliance as it deals with compulsory processes and is easily measured. However, given the recent ethical failures in a number of heavily regulated industries, it was felt that organisations, particularly those in a global marketplace, needed to instill an ethical code of conduct that would direct behaviour in all areas of the business and in all markets.

Read more

GoodCorporation Welcomes Investing in Integrity

This month sees the launch of Investing in Integrity (IiI), an accreditation system which will enable an organisation to demonstrate its commitment to acting responsibly at all times

Designed to build trust, it is a system that can be applied to organisations of all types and sizes.

GoodCorporation has been appointed by the Institute of Business Ethics and the Chartered Institute of Securities and Investment, who developed IiI, to conduct the assessments that will lead to IiI accreditation.

Balfour Beatty and IMI Group have already completed stage one of the management assessment, welcoming the initiative as a vital tool for businesses that enables them to provide assurance of a properly embedded code of ethics.

News and Views

For the latest GoodCorporation views on ethics and responsible practice you can read our thoughts on thegoodblog. We are also on twitter.

Update Autumn 2011

Ethics in the spotlight

With tents pitched around St Paul’s Cathedral, and the City and Church engaged in a dialogue about ethics in the financial services sector, the issue of responsible business behaviour is once again in the spotlight. There have been many calls for greater corporate responsibility since the crash of 2008, but little direction as to what that really means.

From the work we do with companies around the world, we know that many have a clear idea of what corporate responsibility is all about. Our business ethics debates, held this Autumn and written up below, acknowledge the need for a strong ethical culture to permeate throughout an organisation.  From what we see, it is establishing a robust ethical code of conduct that has a real impact on behaviour, rather than simply abiding by rules and regulations.

This debate is becoming increasingly important for businesses and we welcome and support any initiatives to promote it.

GoodCorporation debates ethics versus compliance in Paris

This September, GoodCorporation held its first debate on business ethics in Paris. It was attended by senior figures in the fields of ethics and compliance from some of France’s most prestigious companies including Total, EdF, France-Telecom/Orange, EADS, L’Oreal. Lafarge, Thales and Airbus.

The debate centered on the role of ethics and compliance within an organisation. Led by GoodCorporation client Bernard Claude, Chair of the Ethics Committee at Total, the debate examined the difference between the two functions and asked if they should work together or be kept separate.

It was clear from the discussion that compliance was seen as an essential part of the regulatory framework that governs businesses today. However, it was also felt that compliance alone was not enough to ensure an ethical code of conduct in all areas of business practice. Indeed, there are plenty of examples of heavily regulated industries with dominant compliance functions that have failed to prevent corruption or malpractice.

While compliance takes care of rules and regulation, ethics, it was felt, has a direct influence on behaviour. As business has become more global and both the media and indeed social media have become more far reaching, there has been a corresponding rise in both the importance and the prevalence of codes of conduct and codes of ethics.  Allowing poor ethical conduct is a high-risk strategy with potentially disastrous implications for corporate reputation.

But while few would argue against the need for both a compliance and an ethics function, there was a difference of opinion as to how they should operate within an organisation.  Many felt that they should be kept separate to avoid the possibility of the two functions converging. It was suggested that by keeping the two in distinct departments, it would ensure an equal emphasis on ethical behaviour as well as regulatory compliance and so avoid the establishment of a box-ticking culture.

However, others felt that by keeping the two functions in different departments, there was a risk of Chinese walls, of the left hand not knowing what the right hand was doing and of these two vitally important functions effectively in competition.

Ethics and compliance, it was argued, are two complimentary functions that must operate side by side. This was broadly agreed. Both, it was felt, have equal importance within the corporate structure and whether or not they are in the same or different departments, they must operate together to ensure the same goal.

House of Lords Debate: Ethical challenges in the pharmaceutical sector

At the first GoodCorporation debate on ethics in the pharmaceutical sector the issues of compliance, corporate values and industry standards were widely discussed.

The debate was introduced with a thought provoking analysis of the main ethical concerns for the industry. Pharma is now at a key point with important decisions to be made about commercial governance. Some leading industry figures are stressing the importance of compliance. Others feel that in future, business practices will be driven primarily by values rather than laws. This will involve going beyond legislation and regulation to establish new approaches to stakeholder interactions and build new relationships based on trust and shared values.  Key messages include that ‘competitive advantage in the future will come by distinguishing a company through integrity’.

It was even argued that the law is beginning to get in the way of doing the right thing, inhibiting an ethical path forward. Values, set out in internal and external Codes of Practice, but more importantly embedded in company culture, could and should define future business activities. An important part of this new position is that pharmaceutical companies genuinely act as responsible partners in healthcare, which many industry leaders are talking about.

GoodCorporation’s own work in the pharmaceutical sector supports the view that there are competitive opportunities for companies to obtain from developing aspects of their Codes of Conduct ahead of their industry peers. However, from a society point of view, it is also important that the sector works together to ensure that poor ethical practice is identified and collective action is taken to ensure minimum good standards are in place across the sector as a whole.

In Brief...

Anti-corruption work continues with leading companies

Our work in the Anti Bribery and Corruption (ABC) area continues to grow and we are working across a number of industry sectors to help businesses strengthen practices and procedures in accordance with the new Bribery Act.

In the media and information sector, we have been working with DMGT to refresh their Code of Conduct and draft their ABC policies. As with many companies, we were asked to advise specifically on how to make gifts and hospitality, third party due diligence and whistleblowing more robust.

GoodCorporation has provided valuable guidance, enabling us to strengthen our own ABC policies and processes in a number of areas covered by the new legislation.” Catherine Lye, Risk and Assurance Manager DMGT

What makes a good business?

When Ed Miliband unveiled a Labour policy to reward good companies and penalise bad ones, the idea provoked generally negative business commen.  As advocates of responsible business, we’d like to think there is some merit in it rather than dismissing it as another short-lived Big Idea.

The two key questions it poses are: what distinguishes good from bad and what would these rewards/penalties be?

So what is a ‘good’ business? We would argue that responsibility is at the core of good business. A responsible business tries to be fair to its stakeholders as a whole, namely its own employees, its customers and suppliers, as well as caring about the environment and the community where it operates. A business needs to be successful commercially, and hence create value and jobs, while taking responsibility for all its actions wherever they are carried out.

The complexity and variety of what constitutes good would suggest that the rewards and incentives can’t be a silver bullet, like a tax break, but rather a whole raft of measures. Such as tax incentives for R&D and training carried out in the UK; fines for environmental damage which match the social cost; tougher regulation on mis-selling products and services; penalties for paying suppliers late; disqualification of companies from public contracts if they commit serious corporate offences.

We await with interest further details as they are worked out. But we hope that the beneficiaries would not be chosen solely on the basis of overly simplistic, identifiable criteria.

GoodCorporation announces two senior appointments

GoodCorporation is delighted to welcome two new members of staff who join the team as a result of a number of business wins over the last 12 months.  Debbie Ramsay joins GoodCorporation from the International Business Leaders Forum (IBLF) where she was Marketing and Business Development Director.

Anthony Ruback joins from the Institute for Global Ethics where he was responsible for ethics training programmes.

News and views

For the latest GoodCorporation views on ethics and responsible practice you can read our thoughts on thegoodblog. We are also on Twitter

Update Summer 2011

Welcome to the Summer issue of Update.

It has been an interesting few months for corporate responsibility.  The Bribery Act was finally ushered in after many claims that it would be bad for business, impossible to comply with and would destroy competitiveness. Shortly after the Act came into force, the News International hacking scandal hit the headlines, demonstrating, rather effectively, the reputational damage caused when it appears that corrupt practices and poor business ethics are either tolerated or ignored.

At the Parliamentary Hearing, Rupert Murdoch agreed to cooperate with the enquiry but refused to accept responsibility for what had been going on within his organisation. This is a position that business leaders can no longer afford to adopt, no matter how large and seemingly powerful their company. The CEO’s protestation of innocence on the grounds of not knowing what was happening saved her job for a few days only.

Not only is this unacceptable in the eyes of the public, it is now unacceptable in the eyes of the law.  One of the key changes brought about by the Bribery Act is that directors can no longer say that they had no idea what was going on. Feeling betrayed rather than responsible, as the Murdochs claimed, is simply not an option.

Developing and issuing a code of conduct, but having no idea how employees are informed and educated about the content will not wash.  Best practice will demand that corporate responsibility starts at the top, but filters right down to the bottom.  Businesses will need a rigorous code that is implemented and embedded throughout the organisation.

We work with many leading companies to help them ensure that this is the case. After ten years, I am optimistic that most companies are in forward rather than reverse gear as far as ethical business conduct is concerned. To drive things forward, business needs to embrace ethics in the way it embraced health and safety and the environment. Compliance is an important tool to this end but in many organisations it is often a substitute for ethics.  However, to ensure best practice, compliance and ethical culture will need to pull together to form the bedrock of sound corporate responsibility. Hard though this may be, it will depend on recruiting and retaining people with the right attitude, drumming into them what the leadership expects and ensuring that these expectations permeate the organisation as a whole. Only when this becomes the norm will corporate scandals such as Enron and News International stop hitting the headlines.

Michael Littlechild – director GoodCorporation

Prosecution and Adequate Procedures Under the Bribery Act

Prior to the Bribery Act coming into force, GoodCorporation invited business leaders to debate the impact of the new legislation at the House of Lords.

The debate began with a reminder of the existing law of corporate criminal liability that remains unchanged despite the passing of the Bribery Act. What the new legislation means however, is that the senior leadership team, or the ‘operating mind’ as it was called, can no longer claim a lack of knowledge, turning a blind eye if wrong-doing has been committed within its organisation. Ensuring that Adequate Procedures are in place will provide Boards with knowledge upon which they must act.

The debate covered a number of key areas including facilitation payments, venture partners, intermediaries and agents, corporate hospitality and adequate procedures.

The debate revealed that UK-based companies are preparing seriously for life under the Bribery Act. It was said that if British companies become a benchmark for clarity and ethical leadership it will be good for business and good for the UK. We have the opportunity now to raise the bar and set the tone globally for demand and expectation in terms of business behaviour.

Read More

In Brief...

Preparing for the Act

GoodCorporation has been working in a wide range of sectors including energy, mining, defence, pharmaceuticals, gaming and media, helping businesses in these industries to prepare for the Bribery Act that came into force on July 1st.

GoodCorporation has also worked with international law firms DLA Piper and Sidley Austin to deliver ABC assessments and with Professor Mark Pieth (chair of the OECD Working Group on Bribery).

Read More

GoodCorporation develops global Anti-Corruption Framework

Earlier this year, GoodCorporation was invited to develop a global Anti-Bribery and Corruption Framework with the Basel Institute on Governance – leading experts in corporate governance and compliance, headed up by Mark Pieth, chair of the OECD’s Working Group on Bribery.

Read More

GoodCorporation develops online ethics course for Imperial College

GoodCorporation has developed the Ethics and Professional Standards in Finance course for the internationally renowned Imperial College Business School.

The course has been designed to give students an overall grounding in financial ethics as it will apply to their work post graduation.  It comprises a series of interviews with leading professionals covering seven ethical topics, as well as case studies and discussion points.

 

GoodCorporation attends Pharma Congress in Istanbul

Having worked with companies in the pharmaceutical sector for a number of years, GoodCorporation is keenly aware of the ethical challenges facing the industry.  Evolving developments in law and regulation as well as public opinion on the standards of ethical behaviour were discussed at the International Pharma Congress in Istanbul. GoodCorporation exhibited at the Congress in May alongside the Basel Institute on Governance.

Key players in the pharmaceutical industry gathered to debate the importance of ethical behaviour, reputation and compliance, exchanging views on best practice and highlighting developments in legislation and regulation.

 

News and views

For the latest GoodCorporation views on ethics and responsible practice you can visit our website or read our thoughts on the goodblog. We are also on twitter.

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