Some CEOs hesitate to communicate on corruption prevention; others do it in a very innovative and convincing manner... using a lot of imagination!
I have always emphasized the need for management to state loudly and publicly the company’s ban on corruption. The tone at the top is the base without which an anti-corruption compliance program cannot be efficient. This is also reflected in the fact that all national guidelines addressing the issue of anti-corruption compliance underline the importance of tone at the top.
Years ago, in 2004, when examining how to formulate the first terms of reference for the certification of corporate anti-corruption programs, I noticed that the manner in which companies designed and implemented processes to prevent industrial accidents had many similarities to the one needed to fight corruption.
In the previous chapter, I insisted on the importance of adapting an anti-corruption compliance program to the local social and cultural environment while respecting a zero tolerance for corruption.
Previously, I argued that corruption is not related to a specific culture. That said, I want to expand on the importance of integrating culture into an anti-corruption compliance program.
The importance of the human factor in any anti-corruption compliance program should not be underestimated. After all, individuals pay bribes to other individuals.
An anti-corruption compliance program is important for the board in terms of business strategy and competitiveness. Obtaining business through corrupt practices results in a false sense of security vis-à-vis market expectations and, consequently, produces inappropriate - sometimes even incoherent - decisions by top management regarding business development.
Many compliance officers have voiced frustration that their boards don’t take the anti-corruption compliance issue seriously; that is, that they treat it as a purely legal issue and not as a strategic concern that could significantly impact business development.
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.