You participated in the ETHIC Intelligence Excellence in Compliance Day – how did you find it and was it useful for you and your work?–
The Excellence in Compliance Day was very insightful for me. I am the Director of Corporate Responsibility at Royal HaskoningDHV, an international engineering firm. Recently a decision was taken to include the role of Group Compliance Officer in this position (instead of the position of the Corporate Secretary). I was already a member of the Integrity Council, but now the GCO role is fully ‘on my plate.’ I have had several meetings with Local Compliance Officers and the Integrity Council, and I have been reviewing our Integrity Management System and international developments in anti-corruption. The EIC Day was very helpful to get the latest in that respect. It was an opportunity to share knowledge and experiences with legal and business experts. – –
In your opinion what were the most useful takeaways from the discussions?
I noted many. Key is that integrity used to be about “doing things right” (as a culture and responsibility), while these days it is much more about “proof and prevention” that you are doing things right (compliance documentation and risk management). This requires stricter working procedures, performance reviews and clear tasks and responsibilities for staff (hard instruments), with parallel levels of awareness and understanding remaining important (soft instruments). After an introduction by Richard Bistrong, we spoke about value systems and ‘incentives’ that encourage or entice people to cut corners, cheat or make secret deals (e.g. variable salary based on sales). From a legal perspective, we are dealing with gaps in knowledge, perception and with interpretation difficulties; what is a ‘proportional action program’? How do you categorize risk, impact and relevance? With respect to Royal HaskoningDHV I realized that we need to get a better overview of our legal obligations; for instance with a matrix of positions versus countries, to show specific legal requirements with which we need to comply nationally and internationally. We also need a matrix with integrity risks versus target groups, to explain which specific integrity risks people need to manage (which requires training). We also spoke about the latest ICC materials on anti-corruption, and I decided to look at them much more closely. Further, we spoke about integrity ‘fatigue’; how to keep integrity and compliance alive and relevant? We shared different ideas and practices among the experts around the table.–
What do you think is the best way to communicate on emerging best practices?
The best way, in my view, is to meet and share, while summarizing and referencing more detailed materials. Face-to-face meetings, webinars or conference calls have much more impact, as you need to focus your attention in order to exchange views and ask questions. Traditionally, we “send” a lot; Programs with many talking experts, large documents, extensive websites and long emails. This can be very informative, but how can one act on all this information? I believe it is more helpful to explore the practical relevance among experts and peers. – –
For you as CCO and for Royal HaskoningDHV, an ETHIC Intelligence certified company, what do you see as the challenges of tomorrow in the area of anti-corruption compliance? –
One thing is the commitment of the Board and senior management, and this is already strong. Next is a ‘step up’ in formalization and awareness, and this is being managed by a solid improvement program to ensure we are on top of it. Next thing is to create a heightened alertness and a more open ‘speak-up’ culture, without damaging team work and trust. Every country will need to find the best approach to this. It is partly a bottom up process as we need to take cultural factors into account. For instance; “Speak up” in the Netherlands or Poland is perceived differently than in the UK or Vietnam, and we need to create a local fit to gain trust and appreciation for the global principle. – –
As a certified company you are part of the Excellence in Compliance club. What do you expect from this group?
I am really looking forward to sharing practical experiences and ideas. How do others deal with similar issues? What can I learn, and what might be helpful to others? Again, take the ‘speak up’ line (we have an external service). This only works if we also create more dialogue on the work floor! We have recently introduced an integrity moment at the beginning of each internal meeting. The chairman of the Board has taken the lead, which shows that that he ‘walks the talk’. It is a short exercise, but in every meeting the chair needs to think about it in advance. We provide topics to kick-off, but we trust that it will develop into a valuable exchange of questions, experiences and views (with meeting minutes to feed back to the CCO). It will make our IMS a living and continuously developing system.
Marjolein Demmers, MSc MBA
Former Director Corporate Responsibility and Group Compliance Officer
The ETHIC Intelligence Experts’ Corner is an opportunity for specialists in the field of anti-corruption compliance to express their views on approaches to and developments in the sector. The views expressed in these articles are those of the authors.
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