Evaluating Integrity compliance
Associated almost exclusively with multilateral development banks (MDBs), integrity compliance covers a range of misconduct issues beyond bribery and corruption, including fraud, theft, collusion, coercion and obstructive practices as defined by the Joint International Financial Institution (IFI) Anti-Corruption Task Force.
The World Bank Group and related multilateral financial institutions (MFIs) have strict integrity compliance and governance requirements which place obligations on any organisation in receipt of funds. The penalties for inadequacy are high including debarment, cross-debarment, reputational damage, restricted access to finance and increased financing costs.
What we do
GoodCorporation's evaluation of integrity compliance helps companies ensure that the right systems and processes in place to embed and maintain the required standards.
Managing integrity compliance
GoodCorporation’s Framework on Integrity Compliance can be used to help businesses manage their integrity compliance issues and demonstrate that robust systems are in place.
The four-page framework comprises a set of responsible business principles, which can be used as a tool to assess and improve the robustness of management practices in relation to the risks of misconduct (fraud, corruption, collusion, coercive practices) in an organisation.
It can be used to review head office policies or at site level, to evaluate the application of policies in operating units to help organisations assess whether adequate procedures to prevent bribery are in place.
Use of the framework will help organisations to:
- Demonstrate that they have measured and evaluated their compliance and integrity risks
- Have an appropriate integrity compliance action plan in place to mitigate risks
- Have a system in place that meets international requirements.
Additional integrity compliance support
In addition to the framework, we also provide practical assistance to help companies manage their integrity compliance programmes. This includes: -
- Policy and procedure gap analysis (using the Integrity Compliance Framework)
- Recommending pragmatic improvements
- Preparing detailed implementation plans
- Support to the implementation programme (governance, risk assessment, policy drafting, procedure design, due diligence processes, training…)
Key steps to implementing effective integrity compliance
Implementing effective integrity compliance is a multifaceted process involving all areas of the business.
This will include: -
- Top-level commitment: how to ensure that senior management actively promote the organisation's zero-tolerance of bribery and corruption and other integrity misconduct.
- Communication and training: how to ensure that anti-corruption and integrity policies are understood and properly embedded.
- Risk assessment: how to ensure that the nature and extent of the organisation's exposure to all potential risks of bribery and other integrity misconduct is properly understood, regularly reviewed and effectively mitigated.
- Due diligence: how to apply a proportionate and risk-based approach to due diligence to identify and mitigate any bribery risks from those providing services or operating on behalf of the organisation.
- Key business functions: how to ensure that the organisation can demonstrate it has understood and mitigated the bribery and integrity risks associated with its core business functions.
- Compliance and monitoring: how to implement effective systems to monitor and review the adequacy of anti-bribery and integrity procedures.
Contact Gareth Thomas to discuss your integrity compliance requirements
As the value of integrity states: the interests of the World Bank Group and our clients come first. Corruption and poor governance are major challenges to the institution’s twin goals. One of the best ways to mitigate potential conflicts of interest and corrupt practices is to require transparency and disclosure.
World Bank Group Ethics and Business Conduct Department Annual Fiscal Report 2018
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