When you were first structuring your anti-corruption compliance program, were there any unexpected challenges?
For historical reasons, corruption is a sensitive issue in Slovenia. The state owned banks lost a lot of money during the banking crisis, money that eventually had to be paid back by the taxpayers. In addition, corruption is suspected to be behind a substantial part of that lost money. When, in late 2013, the Bank Assets Management Company took over the majority of non-performing assets from the banks, we were viewed as taking over the corruption as well. We were expected to be non-transparent, trying to cover up for what had happened in the banks. Authorities, politicians and the press were all highly suspicious of the new state owned “bad bank”.
Did we have the policies, the routines and the education to avoid the failings of the banks? At the start we did not, of course, we had to build all that from scratch, which made us open to criticism. We encountered all the challenges of a new organisation, having to take one step at a time, and in an exceptionally hostile environment, where all efforts were questioned or deemed too small or too late. Even the management was accused of being corrupt.
What brought your organisation to the decision to look for possibilities to obtain a form of international certificate in anti-corruption compliance?
Once we had shaped an organisation that was as resistant to corruption as possible, we needed outside help to verify what we had achieved. From an outside, international perspective as domestic Slovenian sources were not sufficiently credible; and even in Slovenia, everyone risked being accused of having conflicts of interest. Being the first company in Slovenia to receive an international anti-corruption certificate was and is important for our credibility. We have to convince not only the authorities, but also the press and the politicians that we have done what we can do to establish an organisation compliant with best international standards. This is why we contacted ETHIC Intelligence. In December 2013, when we took over the first portfolios of assets from the banks, we were just 10 people in the company. One and a half years later, we were close to 100. The anti-corruption issues have been hot from the very start and we have gradually learnt how to work with the authorities. In the beginning, we were heavily criticised by the Slovenian anti-corruption authority, but over time, they also helped us build the necessary organisation and establish relevant policies and staff training programs. The certification process brought us valuable knowledge in our efforts to meet international standards of anti-corruption compliance.
Now that your anti-corruption compliance program is implemented and has been certified by ETHIC Intelligence what are the next steps to ensure ongoing compliance?
Going forward with a good organisation in place, the challenge will be to ensure sufficient surveillance of the program and in regular staff training. We shall also have to communicate again and again on the fact that we have anti-corruption issues foremost in our minds and that will be a challenge in itself. There is a Slovenian anti-corruption program run by a number of commercial companies, and we shall establish a contact with this program. Furthermore, since we own majority stakes in a number of companies, we can try to influence and improve the anti-corruption programs in these companies, bringing them closer to international standards.
How can you encourage other financial institutions to do business with integrity?
Corruption continues to be a global problem but Slovenia is by no means the worst offender. Public resistance to corruption is increasing and the resistance is getting more and more political attention, which is a positive sign. If Slovenian anti-corruption efforts received more support from international bodies specialized on the subject this would be a positive step on the road to ensuring business with integrity in Slovenia.
Chairman of the Management Board
The ETHIC Intelligence Expert’s 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.