Are you familiar with the PDCA (plan-do-check-act) process for the control and continuous improvement of business processes and products? The process is known by many similar names, but the approach is the same. You plan a course of action; you execute the plan (do it); you evaluate the approach and results (check), you make needed adjustments to improve the process or product (act), and then you do it again.
Transparency International, an organization that promotes international anti-corruption efforts, offers a related six-step process. The process, called the business integrity toolkit, is intended to help organizations build effective anti-corruption programs.
Instead of plan-do-check-act, we have commit-assess-plan-act-monitor-report. Here’s how Transparency International describes these six steps, as adapted from its website (link provided below).
Commit to an anti-corruption program from the top.
A company should adopt an anti-corruption program as an expression of core values of integrity and responsibility and as a way to effectively counter corruption. An effective program requires oversight, leadership, and support from the Board of Directors (or equivalent) and senior management.
Action: Express the commitment formally through a written statement published internally and externally.
Assess the current status and risk environment.
A company should conduct a risk assessment before it develops and implements its anti-corruption program. The aim of the risk assessment is to identify areas of greatest inherent risk (for example along geographic or functional lines) and evaluate the effectiveness of existing risk-mitigating measures.
Action: Prioritize and allocate resources appropriately to the areas of greatest risk.
Plan the anti-corruption program.
After completing its risk assessment, a business lays the foundation by developing a plan of action.
Action: Develop policies and procedures that define the scope and activities of the anti-corruption program. Make the policies and procedures available throughout the organization, in the main languages of all employees.
Act on the plan.
As Transparency International says, while many businesses have well planned programs, they fall short on effective implementation.
Action: Translate the written policies and procedures into visible actions that are integrated into organizational structures.
Monitor controls and progress.
A company cannot stop at one-time implementation. It must engage in regular monitoring to identify strengths and weaknesses and to continuously improve its anti-corruption program.
Action: Undertake both internal and external monitoring to build on strengths, eliminate weaknesses, and keep the program up-to-date.
Report internally and externally on the program.
A company that reports on the elements of its anti-corruption program demonstrates the sincerity of its commitment and demonstrates how values and polices are being translated into action.
Action: Report the following types of information to internal and external stakeholders: how the program is being implemented; employee perceptions and attitudes; numbers of inquiries or issues raised through hotlines or other reporting channels; numbers and types of violations detected and related corrective actions taken; and sanctions applied and transactions abandoned because of incidents of corruption.
Reporting raises awareness among employees, influences the company’s reputation, and establishes a common language to measure, compare, discuss, and (continuously) improve anti-corruption activities and practices. And, because continuous improvement is a cycle, the reporting step leads right back to a reassessment of the commitment step, and the cycle continues.
Transparency International’s “business integrity toolkit” web page offers additional information about related business requirements and helpful tools. It’s worth a look!
Feel free to contact Ethical Advocate to discuss information related to ethics and compliance or anti-corruption programs.
Transparency International. “Business Integrity Toolkit,” (web page). http://www.transparency.org/whatwedo/tools/business_integrity_toolkit/0/