Executive Summary - weforum.org

Industry Agenda
18th PACI Task Force
Meeting
Executive Summary
Geneva, Switzerland, 29-30 October 2012
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2012 - All rights reserved.
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REF 141112
Members of the World Economic
Forum’s Partnering Against Corruption
Initiative (PACI) Task Force met on 29-30
October 2012 in Geneva, Switzerland,
to take stock of key Task Force initiatives
and to guide the future direction of PACI.
The meeting coincided with a time of
heightened public, media and business
interest surrounding corruption-related
issues.
The meeting took place over two days.
The first day focused on PACI’s strategic
positioning and activities. The second
day was dedicated to peer-to-peer
networking and the evolving compliance
agenda, featuring special insights into
the areas of law enforcement, technology
and crisis communication.
Executive Summary
3
Day 1 – 29 October 2012
1. A Re-Oriented PACI Strategy
The discussion on PACI strategy was introduced by Alex
Wong, Senior Director, Head of Business Engagement, World
Economic Forum, and led by Elaine K. Dezenski, Senior
Director, Head of Partnering Against Corruption Initiative (PACI),
World Economic Forum.
01: Fifty-two participants took part
in the 18th PACI Task Force Meeting,
which included representation from
50 organizations, 31 Members of
the World Economic Forum, 26
countries, 5 PACI Board delegates
and 5 observers.
01
Anti-Corruption at a Tipping Point
A Strategic Imperative for Chief Executives
The fight against corruption is assuming great importance in
many parts of the world, including Brazil, Canada, India, the
Middle East and North Africa. Recent surveys show that public
trust in business is improving and that business is now seen as
part of the solution to overcoming corruption.
The World Economic Forum has singled out PACI as one of
its recently identified global institutional initiatives, generating
higher visibility and stronger linkages with other segments of
the Forum’s work, including the Network of Global Agenda
Councils and Forum regional objectives. A priority will be to
increase the engagement of chief executives alongside the
community of practitioners who make up the core of the PACI
Task Force.
Never before have corruption and transparency issues been
so strategically crucial for companies and corporate boards.
Global investments continue to migrate to high-growth
emerging markets, many of which are characterized by a lack
of transparency and endemic levels of corruption. The rise of
new global companies from these emerging markets is creating
additional challenges in terms of creating a level playing field
and pushing the boundaries of the global anti-corruption
agenda.
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Partnering Against Corruption Initiative
Stronger emphasis will be placed on corruption as a strategic
enterprise risk issue for business. The Forum’s Global Risks
Report 2012 identified “pervasive entrenched corruption” as
one of the global risks that is most highly interconnected to
the other top 50 global risks studied in the report, including
organized crime, severe income disparity or widespread illicit
trade.
The impact of corruption on growth is also important to
highlight. A combined look at Transparency International’s
Corruption Perceptions Index and the Forum’s Global
Competitiveness Report shows that countries with the highest
levels of perceived corruption are also the ones suffering from
the most profound competitiveness gaps.
The re-oriented PACI strategy will unfold at global, regional and
industry levels:
Strategic
Objectives
For Task Force
Discussion and
Action
–Create a CEO-level
dialogue that links
anti-corruption to
broader strategic
messages about
growth, trade,
competitiveness
and risk resilience
–Secure
implementation
of B20
Regional
–Expand PACI local
networks, building
on the experience
of the PACI
Mongolia Network
–Identify
opportunities
for building
new PACI local
networks at
the regional or
country level
Industry
–Serve the PACI
community
through enhanced
tools and services
–Launch review
of PACI
Principles
Global
–Close gaps
in industry
participation (e.g.
financial services
industry)
–Engage PACI
community
through new
virtual spaces
(TopLink, PACI
Radar)
PACI Community Snapshot
Meeting participants were updated on the current PACI
signatory base:
– Company chief executives have been asked to re-sign their
PACI Commitment Statement by 1 November 2012 or face
possible delisting.
– As of October 2012, 76 company CEOs have re-signed
their PACI Commitment Statement out of a total of 185
PACI signatory companies.
– The objective is to have a total of 100 signatory companies
in 2013 and to engage 15 new signatory companies by
June 2013.
– Regional priorities for PACI recruitment efforts include Asia
and Latin America.
The group was also briefed on the latest changes to
membership, accession and delisting procedures:
– Henceforward, PACI member recruitment will be primarily
limited to existing and new Forum Members.
– In select cases, temporary PACI observer status will be
granted to non-Forum members who are current signatories
of PACI and potential Members of the Forum. This status
will be valid for two years, after which an organization will be
expected to become a Forum Member or leave PACI.
– Signatory companies are required to:
– Re-sign the PACI Commitment Statement every two
years
– Complete the PACI Commitment and Implementation
Survey on signature and thereafter every two years
– Participate in at least one PACI event every two years
– PACI will be requiring all signatory companies to disclose
any issue that could be material to their PACI membership
and that may negatively affect the PACI brand. Such
communication should be made on signature and on
an ongoing basis. PACI will develop guidelines to help
companies determine which type of issues they will be
expected to disclose.
–Foster stronger
links to other
Forum events
(Annual Meeting
in Davos-Klosters
and regional
meetings)
Executive Summary
5
2. Update on Key PACI Initiatives
B20 Recommendations on Improving Transparency and
Anti-Corruption
PACI has played a leading role in the development of the highlevel B20 recommendations on anti-corruption for the annual
gatherings of G20 leaders. Lee Tashjian, Special Assistant to
the Chairman and Chief Executive Officer, Fluor Corporation,
USA, briefed participants on the process.
At the Seoul Summit in 2010, G20 leaders launched the Seoul
Anti-Corruption Action Plan, a nine-point roadmap which
featured a call for enhanced public-private partnership. In the
lead-up to the Cannes Summit in 2011, two CEO-led task
forces were created by the World Economic Forum and the
French business federation MEDEF to formalize business input
into G20 deliberations. The two groups later merged, giving
rise to the B20 Working Group on Improving Transparency and
Anti-Corruption. In Cannes, the Working Group presented a
set of far-ranging recommendations to help G20 governments
implement the Seoul Action Plan.
G20 Leaders’ Los Cabos Declaration, June 2012
(excerpts)
We welcome continuing engagement from
the B20 in the fight against corruption and,
in accordance with the Terms of Reference
of the review mechanism, will involve the
private sector and civil society in the
UNCAC review process on a voluntary
basis.
in 2012, the Working Group identified five core priorities that
were submitted to G20 leaders in advance of the Los Cabos
Summit:
1. Extend the mandate of the G20 Working Group on AntiCorruption to secure implementation of the Seoul Action
Plan
2. Enforce the international legal framework on anti-corruption
and facilitate increased business participation in OECD and
United Nations Convention against Corruption (UNCAC)
peer reviews
3. Promote collective action initiatives and support the creation
of a collective action hub
4. Develop and strengthen capacity building and training
programmes tailored to SMEs
5. Enhance transparency in government procurement
We commit to enforcing anti-corruption
legislation, and we will pursue those who
receive and solicit bribes as well as those
who pay them in line with our countries’
legislation.
G20 leaders incorporated several of the B20 recommendations
in their Los Cabos Declaration (see box), while leaving others
for discussion at future G20 summits.
On 10-11 October 2012, the B20 Working Group met in
Paris with the G20 Working Group on Anti-Corruption. G20
governments voiced their appreciation for the excellent level of
business engagement and expressed their interest in working
jointly with the B20 on the following focus areas: collective
action, legal framework, SMEs and solicitation.
The B20 proposal for a high-level reporting mechanism to
address instances of bribe solicitation drew mixed reactions
from G20 representatives. The Government of Colombia
agreed to pilot test the idea. Public procurement was identified
as a possible fifth topic for joint G20/B20 work, although
G20 governments made clear that this area carried policy
implications which went beyond the issue of transparency and
anti-corruption.
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Partnering Against Corruption Initiative
We extend the mandate of the AntiCorruption Working Group for two years to
the end of 2014.
Next Steps: The Russian G20 Presidency will formally
announce in the coming weeks its priorities for the G20 Summit
in St Petersburg in September 2013. The B20 Task Force
will continue to press for the formation of joint governmentbusiness working groups to drive specific implementation
actions for each of the focus areas.
Third Party Due Diligence Handbook
In 2011, PACI launched a working group charged with
developing a Third Party Due Diligence Handbook, aimed at
helping organizations mitigate the risk of becoming involved
in corruption through third parties (e.g. agents, suppliers, joint
venture partners). Jennifer Quartana Güthoff, Director, Deputy
Chief Ethics Officer, Deloitte, Germany, briefed the group on the
progress of the project.
O ver the past 18 months, the working group has collected
existing materials, conducted interviews, organized content into
a detailed outline (see box) and engaged a professional writer
to develop a first draft. A formal round of consultation on this
first draft was held with key subject matter experts, including
representatives from the OECD, United Nations Office on Drugs
and Crime (UNODC), the UN Global Compact, Transparency
International, the International Chamber of Commerce
(ICC), PACI board delegates and interested PACI Task Force
members.
The Third Party Due Diligence Handbook is meant as a
practitioner’s guide; guidelines provided in the handbook are
intended for all types of businesses. The handbook will not
prescribe specific requirements for identifying which third
parties should be subject to due diligence or for rating thirdparty corruption risk, since these will differ from company to
company.
Next Steps: The handbook is now undergoing external legal
review to ensure that its content is aligned with the imperatives
of critical anti-corruption laws, including the US Foreign Corrupt
Practices Act and the UK Bribery Act. The draft handbook will
be sent to all PACI Task Force members for a final round of
consultation before being formally adopted and published on
the PACI website.
PACI Mongolia Network
The PACI Mongolia Network was launched in 2011 to mobilize
the local business community and to promote joint publicprivate sector dialogue on local corruption challenges. Sambuu
Demberel, Chairman and Chief Executive Officer, Mongolian
National Chamber of Commerce & Industry (MNCCI), Mongolia,
updated the group on this initiative.
To date, about 160 chief executives from Mongolian companies
have joined the PACI Mongolia Network. The initiative started
with a consultative workshop organized with the support of
the Office of the President of Mongolia, the government and
MNCCI. At a second workshop in September 2011, a work
plan was discussed and agreed upon. To drive this effort,
senior representatives from business and government formed a
multistakeholder steering board.
A number of lessons can already be drawn from the PACI
Mongolia Network experience:
– To foster a genuine spirit of collective action, dialogue
between government and business should be based on an
equal partnership.
– Cutting red tape and superfluous business regulations are
powerful means to reduce opportunities for corruption.
– Enforcement efforts play a crucial role in the fight against
corruption; however, the independence of anti-corruption
enforcement agencies and judicial institutions is equally vital.
PACI Vietnam
PACI’s involvement in Vietnam began in 2010 when members
of the World Economic Forum’s Logistics & Transportation
working group selected the country to pilot test solutions to the
challenge of facilitation payments at customs. Joel Fernandes,
Senior Project Manager, PACI, World Economic Forum,
provided a brief update to participants. Three areas for reform
(technology, transparency in rules development and capacity
development) were presented to the Prime Minister of Vietnam
and formally integrated into the Vietnam Customs Reform and
Modernization Plan 2020.
Executive Summary
7
3. Task Force Initiatives for 2012-2013
Participants brainstormed on key initiatives and new projects
that the PACI Task Force should undertake in 2012-2013. The
outcomes of discussions are summarized below:
Implementing B20 Recommendations
– The B20 Working Group on Improving Transparency and
Anti-Corruption has done a remarkable job of developing
substantive policy recommendations; it should now focus
on increased dialogue with G20 governments to drive their
implementation.
– The B20 Working Group will work closely with the newly
appointed Russian Co-Chair of the G20 Working Group on
Anti-Corruption.
– The World Economic Forum, the ICC and the Business
and Industry Advisory Committee to the OECD should
coordinate their approach with the Russian government
and the Russian Union of Industrialists and Entrepreneurs
(RSPP) to facilitate the engagement of companies in
the B20 process and to maximize the impact of B20
recommendations on G20 decisions at the St Petersburg
Summit in September 2013.
Building Regional and Local Networks
– PACI should draw on the experience of the PACI Mongolia
Network to develop and nurture new country- or regionbased initiatives that facilitate dialogue among local
companies and encourage collaborative approaches with
governments on local corruption challenges.
– The local network model has proved an effective vehicle
to spread the word and to mobilize grassroots support for
PACI activities and strategic objectives.
– A framework should be developed to help support the
creation of new regional and local PACI networks. Key
questions to be addressed include: How should success be
measured? What role should PACI have? What monitoring
mechanisms should be implemented to protect the PACI
brand?
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Partnering Against Corruption Initiative
Working Group to Review the PACI Principles
– The international legal context has evolved significantly
since the PACI Principles were initially launched in 2004.
Meanwhile, the ICC Rules on Combating Corruption were
updated in 2011; the Transparency International Business
Principles for Countering Bribery are currently being
refreshed.
– The PACI Principles should remain inspirational while
providing a baseline for benchmarking and tracking
compliance efforts by companies.
– The PACI Principles should continue to focus on bribery
issues. Provisions on risk assessment, due diligence,
whistleblowing and facilitation payments should be revisited
to reflect the latest legal developments and the evolution of
business practices.
- A timeline for the update of the PACI Principles will be
presented at the World Economic Forum Annual Meeting
2013 in Davos-Klosters. A core working group will be
established and will report back to the wider PACI Task
Force.
Promoting Effective Anti-Corruption Legal Frameworks
– The Government of Canada has approached PACI to obtain
business input on the revision of its anti-corruption laws and
other relevant regulations. Other countries could also benefit
from key business recommendations in this area.
– PACI could engage in developing a set of key
recommendations for drafting effective legal frameworks to
fight corruption. Such work could lay the foundation for a
high-level dialogue between CEOs and government leaders.
– Issues to be addressed include the need for effective
enforcement, a clear definition of criminal offences,
whistleblower protection, voluntary disclosure schemes
and “safe harbour” provisions based on globally accepted
compliance standards.
– Several PACI Task Force members expressed interest in
forming a working group to develop a white paper with key
recommendations.
4. Global Update on Projects Driven by
PACI Partner Organizations
UN Global Compact
International Anti-Corruption Academy
Olajobi Makinwa, Head, Transparency and Anti-Corruption;
Coordinator, Senior Civil Society, United Nations Global
Compact, New York, updated the group on the organization’s
activities:
Georg Florian Grabenweger, Policy Adviser, International AntiCorruption Academy (IACA), Austria, introduced the mandate
and activities of the organization:
– New Global Compact sub-working groups are currently
developing anti-corruption tools in the areas of risk
assessment, public-private collaboration, sport sponsorship
and hospitality, and oil and gas.
– The Global Compact will launch its new risk assessment
tool in December 2012.
– On the occasion of the Rio+20 Summit in June 2012, the
Global Compact hosted a Corporate Sustainability Forum
with close to 3,000 participants.
– The Global Compact will be looking to steer business
participation in the UN post-2015 development framework
that will succeed the UN Millennium Development Goals.
– UN Secretary-General Ban Ki-moon has been invited to
address the next meeting of the Global Compact Working
Group on the 10th Principle, to be held on 10 December
2012 in New York.
– Launched in 2010, IACA acquired international organization
status in March 2011.
– IACA is the only global institution solely dedicated to anticorruption education, training, networking and cooperation,
and academic research.
– IACA has a constituency of 58 UN Member States and
holds Observer Status with the United Nations Social and
Economic Council (ECOSOC) and the Council of Europe’s
Group of States against Corruption (GRECO).
– IACA offers a 24-month Master’s programme in AntiCorruption Studies and a 10-day summer academy; a
three-day workshop geared towards journalists from the
Middle East and North Africa was organized in October
2012.
UN Office on Drugs and Crime
Candice Welsch, Chief, Implementation Support Section,
UNODC, Austria, briefed the group on the organization’s
initiatives:
– UNODC is the guardian of the UN Convention against
Corruption (UNCAC); 163 states have ratified the
convention to date.
– A priority for UNODC is to work more closely with the
private sector on issues related to the implementation of
UNCAC; the private sector has already participated in 28
country reviews under the UNCAC review mechanism.
– UNODC and the UN Global Compact jointly produced
an e-learning tool (http://thefightagainstcorruption.
unglobalcompact.org) to help companies better understand
UNCAC and its implications for the private sector.
– With the support of the Siemens Integrity Initiative, UNODC
has created two working groups: one on legal incentives
to support companies’ integrity efforts and encourage the
voluntary reporting of incidents of corruption, and on probity
in public procurement. In addition to a global segment, the
two projects include a set of activities in India and Mexico.
– UNODC has launched a new workstream to address the
issue of corruption in the context of major public events,
such as Olympic Games and G20 summits, which typically
entail large expenditures, the use of sponsorships and the
setting up of temporary government agencies.
Executive Summary
9
5. TopLink and PACI Radar
Carolina de Jong, Senior Team Coordinator, PACI, World
Economic Forum, introduced the group to TopLink and the
PACI Radar, two virtual spaces designed to facilitate greater
collaboration and information-sharing among PACI members.
TopLink is a collaborative intelligence platform that combines
Facebook-type social networking facilities with Skype-type
communication functions. The service is available to all Forum
Members and includes a PACI-only section through which
users can share information about their compliance activities,
chat with each other, run polls and work on collaborative
documents. TopLink operates as a closed social network.
Its high level of security allows participants to exchange
confidential information and engage in private discussions with
their peers.
PACI Radar is a news, analysis and data platform dedicated
to PACI members. This website will feature information
about ongoing PACI activities and allow users to easily
access relevant PACI resources such as PACI surveys, B20
recommendations and the collective action case studies
developed by McKinsey. Introduced in its beta version at the
Task Force meeting, the PACI Radar – to be formally launched
at the World Economic Forum Annual Meeting 2013 in DavosKlosters in January – will be the first version of a database with
country-based information to help users assess corruption risks
and understand the linkages between corruption and other
indices developed for The Global Competitiveness Report.
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Partnering Against Corruption Initiative
Day 2 – 30 October 2012
1. The Evolving Anti-Corruption Agenda:
High-Level Plenary Session
The aim of this high-level plenary session was to explore
the changing nature of corruption and to examine how new
approaches, based on enforcement, technology and public
participation, can help deter corrupt practices.
– Technological applications have transformed everyday
processes, such as applying for a passport or buying a train
ticket, by eliminating the need for middlemen and thereby
removing opportunities for petty corruption.
Rob Wainwright, Director, Europol (European Police), The
Hague, and Member of the Global Agenda Council on
Organized Crime, stressed the linkages between corruption
and organized crime:
Carlos Moreira, Chairman, Chief Executive Officer and Founder,
WISeKey, Switzerland, explored the role of technology in
fighting economic crimes:
– The size of the informal economy is mind-boggling; up to
100 billion euros are estimated to be lost every year as a
result of VAT fraud in the European Union.
– Organized crime groups are moving away from the
hierarchical, mafia-type model and increasingly operate
as small, mobile and entrepreneurial groups across large
territories.
– Smuggling drugs or counterfeit cigarettes depends largely
on the ability of these groups to corrupt border officials;
corruption remains a primary enabler of organized crime.
– The Internet has become a privileged medium for organized
crime activities. Cyberspace is home to vast information
assets, networks and systems that are highly vulnerable to
attacks; cyber threats have been identified as a major risk
for global supply chains.
– New technology applications are seriously complicating
the work of counterfeiters. ID chips can now be inserted
in jewellery and watches and serve as certificates of
authenticity; pharmaceutical companies use laser engraving
to counter fake drugs.
– Companies are increasingly challenged by consumers on
security issues; businesses that do not use technology to
protect their assets are perceived as negligent.
– As we move to a digital society and more sophisticated IT
systems, it will be increasingly uncommon for one individual
to have complete control over a business process or
unrestricted access to large databases. This should help
reduce the scope for corruption and the theft of data.
Corruption remains a primary enabler of
organized crime.
Technology will not make corruption
disappear completely, but it will make
corrupt practices much more difficult to
carry out.
Rob Wainwright
Director, Europol (European Police), The Hague
Carlos Moreira
Chief Executive Officer and Founder, WISeKey, Switzerland
Sachin Taparia, Chairman and Managing Director, New Venture
and Member of the Advisory Board, TVS & Sons Limited, India,
discussed the evolution of public attitudes towards corruption
in India:
Kenneth Zhang Yixiao, Chief Executive Officer, Haohe
Engineering and Construction Co., People’s Republic of China,
shared feedback on China’s experience in fighting corruption:
– While the Indian economy has grown at an average of
7% over recent years, the pace of development has been
substantially lower. About 3% of GDP growth is lost every
year as a result of inefficiencies in infrastructure, education
and access to basic necessities.
– India has recently experienced its first social movement
against corruption; for the first time in the country’s history,
citizens are coming together to denounce widespread
corruption at all levels of society.
– Technology has played a huge role in this social movement.
Through initiatives like the “I paid a bribe” website (www.
ipaidabribe.com), information about corrupt practices and
corrupt officials now reaches the local media very fast and
provides immediate social feedback.
– Anti-corruption efforts have been gaining momentum in
China. The reduction in the number of government permits
and approvals required for large infrastructure projects has
proven particularly effective for removing opportunities of
corruption.
– The level of transparency in public procurement procedures
has increased significantly. Many application and approval
processes are now run online; the government has
organized public hearings for the award of power generation
projects.
– China’s microblogging website Sina Weibo played a
significant role in boosting the country’s anti-corruption
efforts; several corrupt officials have been exposed by
Chinese bloggers.
– Haohe Engineering and Construction is the first Chinese
company to have joined PACI.
Executive Summary
11
2. The Evolving Anti-Corruption Agenda:
Break-out Sessions
Break-out sessions gave PACI members an opportunity to
exchange further thoughts and ideas with guest speakers. Key
points from these sessions are summarized below.
Enhancing cooperation between law enforcement
and business
– Corruption is not a consistent priority for law enforcement
agencies, since much of their resources and coordination
efforts are currently focused on terrorism.
– Many companies have reported difficulties in understanding
the investigation process for cases of corruption and in
creating an atmosphere of cooperation and trust with law
enforcement authorities.
– The new whistleblowing provisions introduced by the
Dodd-Frank Act in the United States have raised concerns
about the risk of encouraging false claims with potentially
devastating consequences for companies.
12
Partnering Against Corruption Initiative
Explore how technology improves visibility across
global supply chain networks
– There are obvious limits in the power of technology to
increase transparency and eliminate corruption since
corrupt practices are often hidden and impossible to trace.
– Technology could bring important benefits in two ways:
by helping to identify patterns of corrupt practices; and by
helping organizations conduct their due diligence activities
and manage large quantities of data on their third parties.
– Many companies have faced difficulties in complying with
both their due diligence obligations and data privacy laws
(which restrict access to personal information of third
parties).
Business-to-business transactional integrity
– Ethical business practices should become a business
differentiator across supply chains. This could be achieved
by creating incentives such as white lists and access to
preferred supplier status.
– The business case for anti-corruption is easier to make
for large multinational companies (which face higher
enforcement scrutiny) than for SMEs. Therefore, large
companies have an important role to play in sending market
signals in support of integrity practices.
3. iShare – Sharing of Best Practices
through Speed Networking
Speed networking is a business networking activity through
which participants make initial contact with as many people
as possible in a short period of time. Through this interactive
exercise, Task Force members shared and received feedback
on one key compliance-related challenge they are currently
facing. The topics addressed by participants included:
– How to promote a culture of ethics and compliance in an
organization
– How best to organize the compliance function within a
company
– Risk-based versus rules-based compliance programmes
– Control procedures to monitor the implementation of
compliance programmes
Speed networking is a great way to
maximize the use of time at PACI
meetings. In the last hour, I shared views
with compliance experts from a global
consultancy firm, a public relations
company, the OECD and one of my
company’s largest contractors.
Michele De Rosa, Topic Leader, Antibribery, Sustainability and Internal
Control System, Eni, United Kingdom
4. Communication in Times of Crisis
Joachim Klewes, Senior Partner, Ketchum Pleon, Germany, led
an interactive session aimed at helping PACI members improve
their company’s communication response in the event they are
faced with a compliance crisis.
Corporate communications is a management function or
department dedicated to the dissemination of information to
key constituencies. This function serves as the conscience
of the corporation and is responsible for the organization’s
reputation (Source: Financial Times Lexicon).
Instances (or mere allegations) of corruption pose considerable
reputational risks for companies. However, most heads of
communications tend to see compliance as just one of the
important topics they have to monitor, alongside health,
safety and environmental risks. Because compliance crises
often go to the top of the company, communications and
compliance departments should work together to make sure
that compliance issues are properly taken into account in the
company’s crisis communication strategy.
Task Force members took part in an interactive simulation
based on a real-life scenario. Participants were asked to identify
effective communication activities that a company can use
when faced with allegations of corruption in the media. Possible
external and internal communication responses included the
following:
– Issue a holding message acknowledging the claims and
informing stakeholders that “the company will look into the
matter”.
– Do not seek to deny accusations until you possess
sufficiently robust information that rules out any wrongdoing
on the company’s part. Be humble in your tone.
– Try to “cut the news cycle” by issuing a succinct but timely
press release. Sometimes silence will only perpetuate the
news cycle.
– Ensure that the company speaks with one voice. Prepare
speaking points for executives and staff members.
– Issue a general statement expressing your company’s
commitment to continue to act with integrity and in
compliance with the law.
– Quietly begin to investigate. Make senior executives, and
possibly the Audit Committee, aware of the accusations and
of the launch of an internal investigation.
– Start by querying the results of any past due diligence that
was performed on the business unit or employee facing
the accusations. The ultimate goal is to verify whether the
rumours are substantiated or not.
– At all times, demonstrate to key audiences that the
company is credible in the way it deals with the situation.
Executive Summary
13
5. Conclusion:
Sharing Key Takeaways
Elaine K. Dezenski, Senior Director, Head of PACI, World
Economic Forum, closed the meeting by thanking participants
for their inputs on PACI strategic orientation and future
activities. PACI members were invited to express their interest
in joining the following PACI working groups for 2012-2013:
– B20 Working Group on Improving Transparency and AntiCorruption
– PACI Working Group on the Update of the PACI Principles
– PACI Working Group on Key Recommendations for Effective
Legal Frameworks
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Partnering Against Corruption Initiative
6. Final List of Participants
PACI Members and Partners
Jason A. Lomax
Director of Competition Law &
Anticorruption Law
Accenture
USA
Catherine Eikland
Head, Anti-Corruption Program Office
Alcatel-Lucent SA
France
Guillermo Erasmus
Assistant General Counsel
AngloGold Ashanti Ltd
South Africa
Jenny Baster
Group Legal Director
Arup Group Ltd
United Kingdom
Damian Heller
Manager, Compliance Practice
Basel Institute on Governance
Switzerland
Faiza Alleg
Junior Legal Counsel, EMEA Regional
Office
Boart Longyear
Switzerland
Bernard Masters
Vice-President and Associate General
Counsel
Boart Longyear
USA
Patricia Barratt
Senior Associate
Clifford Chance LLP
United Kingdom
Tony Awad
Group Corporate Social Responsibility
Officer
Consolidated Contractors
Company (CCC)
Greece
Ken B. Graversen
Officer, Corporate Ethics and
Compliance
Danfoss A/S
Denmark
Jennifer Quartana
Guthoff
Director, Deputy Chief Ethics Officer
Deloitte
Germany
Garry Kemp
Senior Vice-President, Compliance
DHL Express
Hong Kong SAR
Randy Corley
Global Compliance Officer
Edelman
USA
Stefan Reus
Corporate Compliance
EnBW Energie Baden- Württemberg AG
Germany
Michele De Rosa
Topic Leader, Antibribery, Sustainability
and Internal Control System
Eni SpA
Italy
Maaike de Bie
Director, Global Corporate Counsel
Ernst & Young
United Kingdom
Thembeka Ndaba
Executive Manager, Forensic Services
Eskom Holdings SOC Limited
South Africa
Lee Charles Tashjian
Special Assistant to the Chairman and
Chief Executive Officer
Fluor Corporation
USA
Kenneth Zhang Yixiao
Chief Executive Officer
Haohe Engineering and Construction
Co. Ltd
People’s Republic of China
Gernot Dresch
Chief Compliance Officer
Hilti Aktiengesellschaft
Liechtenstein
Marie-Christine von der Groeben
Head of Compliance Awareness &
Prevention
MAN SE
Germany
Markus Heyer
Corporate Ethics and Compliance
Officer
Panalpina World Transport Holding Ltd
Switzerland
Iain Heydon
Manager, Corporate Compliance, Africa,
China and Asia-Pacific
Panalpina World Transport
Holding Ltd
Switzerland
Luiz Claudio Schleder Sampaio
de Almeida
Coordinator of Transparency
Petroleo Brasileiro SA – Petrobras
Brazil
Didier Lavion
Principal - Forensic Services at
PricewaterhouseCoopers LLP
USA
Andrew Hartley
Chief Compliance Officer
Pöyry Plc
Finland
Neville Tiffen
Global Head of Compliance
Rio Tinto
Australia
Sabine Zindera
Vice President, Corporate Legal and
Compliance
Siemens AG
Germany
Lars Björklund
Vice-President, Ethics
Skanska AB
Sweden
Marie-Josée Bérubé
Vice-President, Administration
SNC-Lavalin Group
Canada
Anne-Helen Lunde
Attorney
Statoil
Norway
John Lewis
Senior Managing Compliance Counsel
and Global Anti-Bribery Counsel
The Coca-Cola Company
USA
Susan Cote-Freeman
Programme Manager
Transparency International
USA
Joost Wiebenga
Deputy General Counsel & Chief
Compliance Counsel EMEA
Tyco International
Netherlands
Frederik Verhasselt
Corporate Security Officer
Umicore
Belgium
Irina Lazieva
Regional Ethics and Compliance
Counsel, FSU and Europe
Weatherford International
Russian Federation
Carlos Moreira
Chairman, Chief Executive Officer and
Founder
WISeKey SA
Switzerland
16
Partnering Against Corruption Initiative
Special Guests
Rob Wainwright
Director
Europol (European Police)
Netherlands
Georg Florian
Grabenweger
Policy Advisor
International Anti- Corruption Academy
Austria
Francois Vincke
Head, Anti-Corruption Commission
International Chamber of
Commerce (ICC)
France
Joachim Klewes
Senior Partner
Ketchum Pleon Gmbh
Germany
Sambuu Demberel
Chairman and Chief Executive Officer
Mongolian National Chamber of
Commerce & Industry
Mongolia
Nejla Saula
Legal Adviser, Sherpa Office, General
Secretariat
Organisation for Economic Co-operation
and Development (OECD)
France
Imelda Dunlop
Executive Director
Pearl Initiative
United Arab Emirates
Brook Horowitz
Executive Director
The International Business
Leaders Forum (IBLF)
United Kingdom
Olajobi Makinwa
Head, Transparency and AntiCorruption; Coordinator, Senior Civil
Society
The United Nations Global
Compact
USA
Candice Welsch
Chief, Implementation Support Section
United Nations Office on
Drugs and Crime (UNODC)
Austria
Hans Brutsch
Head of Compliance
Adecco Group
Switzerland
Thomas Etter
Global Head of Compliance
Damco International A/S
Denmark
Danielle Cannata
International Trade Counsel
Saudi Basic Industries
Corporation (SABIC)
USA
Jan Coos Geesink
SVP, Financial Crime & Reputational
Risk
Thomson Reuters
United Kingdom
Sachin Taparia
Chairman and Managing Director, New
Venture and Member of the Advisory
Board
TVS & Sons Limited
India
PACI Observers
From the World Economic Forum
Elaine K. Dezenski
Senior Director, Head of Partnering
Against Corruption Initiative (PACI)
World Economic Forum
Switzerland
Alex Wong
Senior Director, Head of Business
Engagement (Geneva) and Head of
Basic & Infrastructure Industries
World Economic Forum
Switzerland
Joel Fernandes
Senior Project Manager, of Partnering
Against Corruption Initiative (PACI)
World Economic Forum
Switzerland
Carolina de Jong
Senior Coordinator of Partnering
Against Corruption Initiative (PACI)
World Economic Forum
Switzerland
Ellie Smith
Intern, Partnering Against Corruption
Initiative (PACI)
World Economic Forum
Switzerland
Tuvshinbat
Narmandakh
Associate, Partnering Against
Corruption Initiative (PACI)
World Economic Forum
Switzerland
Sarah-Jane Boulos
Associate Director, FTI Consulting and
Secondee, World Economic Forum
World Economic Forum
Switzerland
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Executive Summary
17
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