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Anti-Corruption Compliance Blog - Published: 01 February 2017
Philippe Montigny
President of ETHIC Intelligence - Paris
Collective actions are not going to curb global corruption overnight. However, at a local level, or in a given sector, they demonstrate that corruption is not inevitable and that results – even limited results - can be obtained.

The last decade has seen a surge of collective actions at the initiative of civil society, professional federations or international organizations. Many have benefited from the support of the Siemens Integrity Initiative which has demonstrated the usefulness of such actions in the fight against corruption at the local level.

What is a Collective Action? 

I first heard this expression 12 years ago and it came from Mark Pieth, President, Basel Institute on Governance and then President of the OECD Anti-Bribery Working Group. We were in a restaurant in Basel, and Mark drew on a paper napkin a triangle with the words Companies, Government and Civil Society at each angle. Pointing his pen to the center of the triangle he wrote “TRUST” and explained that “a collective action is what helps build trust between these three components of society”.

I still hold this definition to be the best. It helps to explain what the following collective actions have in common:

  • The International Forum on Business Ethical Conduct (IFBEC) launched by European and US defense companies to promote anti-corruption best practices 
  • The High-Level Reporting Mechanism to report cases of fraud and corruption in publicly financed projects promoted by the OECD 
  • The Integrity Network Initiative in Egypt designed by local entrepreneurs to help companies, particularly small companies, prevent corruption and resist extortion solicitations
  • The Tainted Assets Initiative on mergers & acquisitions whose aim is to design best practices for pre-acquisition due diligence that would be accepted by enforcement authorities, companies and NGOs. 
  • The Oil and Energy Forum Against Corruption, a 2015 Total-led initiative constituted of a consortium of companies from the energy sector and their subsidiaries, aimed at cooperating to prevent corruption in Gabon.

What makes a Collective Action successful?

Collective Actions are very recent initiatives, yet research has already been done by academics in both the US and in Europe on the subject. As collective actions strive to develop trust among various stakeholders, it is difficult to quantify their impact, yet numerous case studies help provide some understanding of what contributes to the success of a collective action.

From my observations, I retained one principle: A successful collective action is one which is tailor-made to address an identified need with achievable goals. This means that it has to be extremely practical and people-oriented. Gemma Aiolfi, Head of Compliance and Corporate Governance / Collective Action at the Basel Institute, summarized it nicely during a Conference dedicated to this issue by stating: “Collective action is a journey, where every step matters”.

Collective actions are not going to curb global corruption overnight. However, at a local level, or in each sector, they demonstrate that although corruption is not inevitable, results – even limited ones - can be obtained. Collective actions are taking place in areas and sectors in which corruption is a challenge and many initiatives are very innovative. It is a learning curve where it is important to take stock from both successes and failures.

What should the next step be in the development of Collective Actions?

My business takes me all over the world, particularly to countries in which corruption is endemic. When in such countries, I am always struck by the high number of people that are convinced nothing can be done to stop corruption. Collective actions demonstrate the opposite; they show that with a few well-intentioned, determined and imaginative people, it is possible to design and implement innovative solutions which will, slowly but surely, change old patterns of behavior.

Hence why I believe more publicity should be given to collective actions. Successful stories should be broadcast, not necessarily to encourage their duplication, but to stimulate innovation and inspire local and sectoral initiatives.

I mentioned previously that Mark Pieth characterized Collective Actions as a way to build “TRUST”. I would add that Collective Actions also bring “HOPE”.

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About Philippe Montigny

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Philippe Montigny is the founder of ETHIC Intelligence, a leading anti-corruption certification agency that has been certifying companies since 2006. He is currently the Chairman of the Technical and Impartiality committees and has over 20 years of experience in anti-corruption compliance, beginning at the Office of the OECD Secretary-General, for which he was involved in the ministerial negotiations that led to the OECD Anti-Bribery Convention in 1997. Philippe Montigny was also a co-drafter of the compliance management system standard (ISO 19600) published in 2014 and of the anti-bribery management system standard (ISO 37001) published in 2016 and served as ISO liaison officer between the two.

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