TRAC: TRANSPRENCY IN REPORTING OF Social responsibility and an Anti-Corruption Compliance Culture 26 th September 2013 David Coates Senior Advisor Transparency International UK

At home with Ethics and Compliance

Ethical, Legal and Socially Responsible

Transparency International Specialist Anti-Corruption NGO Founded in 1993 TI National Chapters in over 100 countries Proetica

Transparency International’s approach Bribery of any kind embeds corruption in the system Corruption has victims Fighting corruption often requires collective action to achieve systemic change Zero tolerance

Common Excuses For Paying Bribes 6 IGNORANCE “If only we'd known that it would be regarded as a bribe…” COMPLACENCY “We’ve always done it…” SIEGE MENTALITY “We can only compete if…” PRETENDING IT’S NOT A BRIBE “It was only a helicopter trip and a five-course banquet for him and his partner…” OUTSOURCING BRIBERY “We had no idea our agent was paying…” CITING CUSTOM “That’s the way things work here - it’s different…” INADEQUACY “We thought our anti-bribery systems were up to the job…”

Likelihood of companies to bribe abroad by sector … 0 = Always

8 Where does Corruption Take Place? Corruption can also exist between private-sector parties, their proxies or agents Grey area between public and private sectors makes public/private distinction increasingly obsolete

UK Bribery Act Section 7 - Failure by a commercial organisation to prevent a bribe being paid for or on its behalf. –Critical Motivator for Social Responsibility –MoJ Guidelines 6 principles ‘Adequate Procedures’ –Bad Apple Mitigation 9

Adequate Procedures –High-level commitment –Risk assessment –Policies and Procedures –Implementation (e.g. training, communication) –Due diligence assessment of partners, agents and contractors –Monitoring and evaluation 10

Need to Merge

Questions and Thank you David Coates +44 (0)