This medieval chant I like. Given my work in the compliance management, I have three options to apply it to today’s environment:
1. Integrity is dead! Long live Integrity
2. Corruption is dead! Long live Corruption!
3. Corruption is dead! Long live Anti-Corruption!
Let’s assume that it makes sense to focus on 1. and 3.
It should be our modern-day mantra, allowing for every fad, survey, or new statistic to loudly proclaim that Integrity and Anti-Corruption are alive and have to be reinforced as we move along.
The concept of Integrity and Anti-Corruption as we know it is timeless. It’s not broken or inadequate, it simply needs a more specific focus and real attention to application and – in the end – implementation. We just don’t do it that well. Let’s unpack this a bit, fleshing out the realities of Integrity and Anti-Corruption as we know it compared with Integrity and Anti-Corruption as it should be.
What I am driving at is that Anti-Corruption has to be more than lip-service. As we clearly outline again and again that signing an Integrity Pledge is only the first step in a long adjustment process – from tone from the top, to a common code of conduct, from control measures throughout the organization to compliance programs and compliance training, from ‘validation’ processes to certification.
In the new anti-corruption environment, trust is a big deal. Trust has to be there until there is evidence of breach of trust. The new ‘King’ wants a shift to focus on results over process. Management has to lead by example; remember, leading by example is not a choice – it has to be demonstrated daily.
The new King (Anti-Corruption) expects much more involvement of management in anti-corruption implementation. That involvement must lead to the appointment of compliance officers. The first big challenge coming up is for all organizations in the country to live with, comply with the Data Privacy Act and its IRR. Why am I highlighting this? Breach of data privacy is a criminal offence!! HR managers have to be under stress and lawyers have a new source of income.
Is your company using employee data ethically? Do we understand our company’s privacy comfort zone? Do we get guidance from our information governance committee? Do we share guidance with our team and encourage best practices? Do we invite feedback?
In the end of the day: the new ‘King’ wants everybody to have Integrity; I hope you remember the slogan of the Integrity Initiative: “Integrity starts with I”. We have to be honest, consistent, and do what we say we will do!
I forgot to comment on 2. Corruption is dead! Long live Corruption!
Unfortunately, people involved in the many forms of corruption are continuously finding new ways to benefit from this formula: Corruption = Monopoly + Discretion – Accountability.
Anti-corruption and having integrity is tough – wear a helmet!
Feedback is more than welcome; contact me at schumacher@eitsc.com