Business Integrity Forum Peter van Veen, Director, Business Integrity Programme Transparency International UK (TI-UK)

Aims- Corporate Anti-Corruption Benchmark Benchmark of good practice in corporate anti-corruption programmes Allow companies to compare against each other across Industries Identify emerging practice Identify best practice amongst participating companies Highlight different approaches used by companies Inform the development of Transparency International’s tools and indices

The ‘Business Integrity Framework’

Structure of the Benchmark HIGH LEVEL REVIEW 6 Sections 39 questions HIGH LEVEL REVIEW 6 Sections 39 questions DETAILED REVIEW 6 Sections 40 Topics 240 questions DETAILED REVIEW 6 Sections 40 Topics 240 questions SPECIALIST SUBJECTS In-depth look into topics SPECIALIST SUBJECTS In-depth look into topics Alignment with the PHP Companies Index (CI) Alignment with: - Business Principles for Countering Bribery - TRAC - TI-UK Guidance, e.g.: - Risk Assessment - M&A Due Diligence - Small Bribes Specialist Subjects have included to date: - 3 rd Party Management - Incentive Structures

Question Topics Section I – Commit Publicly stated commitment to a policy of prohibition of bribery and corruption Commitment to implementing an anti-bribery Programme Consistency with laws Leadership (‘tone at the top’) Participation in anti-corruption initiatives Section II – Plan (& Design) Policies & procedures Plan and design based on risk assessment Section II – Assess Risk assessment Section IV – Act (Implement) Communication of policies and procedures Training on policies and procedures Due diligence on third parties Conflicts of interest Political activities Charitable contributions and community investments Sponsorships Small bribes including facilitation payments Gifts, hospitality and travel expenses Subsidiaries and controlled entities Joint ventures and consortia Agents and other intermediaries Contractors and suppliers Organisational HR Sales and marketing Contracting and procurement Support functions Communications Stakeholder engagement Education and training Advice and whistleblowing channels Internal controls Incidents including cooperation with authorities Collective action Nepotism, cronyism and patronage Section V – Monitor (& Review) Monitoring of policies and procedures Senior management and Board review of policies and procedures Monitoring and review including benchmarking Assurance and certification Section VI – Report Public reporting on policies and procedures TRAC - Public reporting on anti-corruption Programmes, country-by-country reporting and organisational transparency

Landing Page: Companies Index + Full Report Landing Page: High-Level Report + Full Report

High-Level Breakdown

Full Report Overview

Full Report Question Breakdown

Participants Full DataHigh-level Data BarclaysAccentureMeggitt BPAirbus GroupMitsubishi Electric GSKBAE SystemsNEC Corp. HSBCBalfour BeattyOUP Lloyds BankBechtelRheinmetall RBSBoeing GroupRolls-Royce ShellCSCSafran Tullow OilFinmeccanicaSerco UnileverFluorStora Enso VodafoneFujitsuTUI Travel GE AviationUnited Technologies Hewlett-PackardWeir Group Honeywell