1、Business Integrity:A Toolkit for Medium-Sized EnterprisesW H I T E P A P E RS E P T E M B E R 2 0 2 4ContentsForeword 3Preface 4Executive summary 5Introduction 61 Anti-corruption and bribery risks 101.1 Application in practice 122 Create the foundation 192.1 Ethics committee 192.2 Risk assessment fr

2、amework 203 Anti-corruption policy 243.1 Benefits of an anti-corruption policy 243.2 Implementation tips 243.3 Model anti-corruption policy 254 Financial crime clause 284.1 Benefits of a financial crime clause 284.2 Implementation tips 284.3 Template for financial crime clause 285 Conflict of intere

3、st 315.1 Benefits of a conflict of interest form 315.2 Implementation tips 315.3 Template for conflict of interest form 326 Complaints framework 346.1 Benefits of a complaints framework 346.2 Implementation tips 346.3 Building a complaints framework 35Conclusion 40Contributors 41Endnotes 42Images:Ge

4、tty Images,UnsplashDisclaimer This document is published by the World Economic Forum as a contribution to a project,insight area or interaction.The findings,interpretations and conclusions expressed herein are a result of a collaborative process facilitated and endorsed by the World Economic Forum b

5、ut whose results do not necessarily represent the views of the World Economic Forum,nor the entirety of its Members,Partners or other stakeholders.2024 World Economic Forum.All rights reserved.No part of this publication may be reproduced or transmitted in any form or by any means,including photocop

6、ying and recording,or by any information storage and retrieval system.Business Integrity:A Toolkit for Medium-Sized Enterprises2ForewordThe foundations of strong,resilient economies andpeaceful,inclusive societies are built upon good governance and trust.Bribery,corruption and the abuse of entrusted

7、 power for private gain cause them to crumble.It is imperative,therefore,that business,civil society and governments come together and tackle this systemic challenge.Given this context,it has become increasingly clear that achieving integrity beyond compliance is essential.Sustainability practices,a

8、nchored by robust anti-corruption initiatives,may help ensure that businesses commit to ethical practices that resonate throughout their operations.Small and medium enterprises(SMEs)are the backbone of our global economy and key to this endeavour.They serve as vital links in value chains that stretc

9、h across continents while generating jobs and driving growth within local communities.According to the World Trade Organization,they represent over 90%of the business population,60-70%of employment and 55%of gross domestic product(GDP)in developed economies.Yet,they often operate with limited resour

10、ces and inchallenging business environments,where the risks of corruption can hinder their success and access to opportunities,and at times,threaten theirvery survival.To help address these challenges,Transparency International and the World Economic Forum have joined forces.As the leading organizat

11、ion globally dedicated to promoting transparency andaccountability in governance,and renowned for its flagship Annual Corruption Perceptions Index,Transparency International plays a pivotal role in raising awareness,shaping policy and driving reforms that combat corruption across the world.Since its

12、 inception,the World Economic Forum has convened leaders from all sectors of society toform communities of action to build initiatives forcooperation and progress.To this end,the Forum is bringing together companies,civil society,academia and governments to create solutions that build on efforts by

13、Transparency International to provide SMEs with the tools and resources needed in order to actively mitigate bribery and corruption-related risks.Together Transparency International and the World Economic Forum have developed Business Integrity:A Toolkit forMedium-Sized Enterprises.This practical gu

14、ide empowers medium-sized enterprises with the knowledge and resources to embed integrity at the core of their operations.By doing so,they can not only protect their reputation,but also enhance their competitiveness,and increase their resilience inademanding global market.Finally,the importance of m

15、ultistakeholder collective action cannot be overstated;by working together,businesses,governments and civil society can amplify shared impact,driving systemic change forbetter business environment.Francois Valrian Chair,Transparency InternationalAlois Zwinggi Managing Director,World Economic ForumBu

16、siness Integrity:A Toolkit for Medium-Sized EnterprisesSeptember 2024Business Integrity:A Toolkit for Medium-Sized Enterprises3PrefaceThe World Economic Forums Good Governance Community strives to fortify governance frameworks to promote a landscape of certainty,resilience and reliability.Led by the

17、 Community of Chief Legal Officers,it champions collective action with the aim of driving progress towards United Nations(UN)Sustainable Development Goal 16:Peace,Justice and Strong Institutions.Addressing business integrity challenges is a key priority for the community.Integrity is not just a mora

18、l imperative;it is a proven driver of business success.Conversely,corruption and bribery are detrimental to business health,acting as significant barriers to growth and investment.In some contexts,corruption is the single most critical factor hindering investment growth.Recognizing this,Transparency

19、 International and the World Economic Forum have joined forces to support companies globally in cultivating the skills necessary to prevent corruption and enhance business integrity.This report functions as a toolkit specifically designed for small-and medium-sized enterprises(SMEs)to embed integrit

20、y into their business strategies effectively and help drive their business growth,especially by integrating into the supply chains of larger multinationals.It provides a practical,step-by-step guide to help SMEs develop comprehensive anti-corruption measures and build a culture of integrity within t

21、heir organizations.SMEs account for over 95%of private sector enterprises in most countries globally and form a significant part of multinational supply chains.This report addresses the unique challenges SMEs face in mitigating governance-related risks,ranging from internal fraud and employment prac

22、tices that enable unethical behaviours to business financing and high-risk customer approaches,such as organized crime and illegal trading.Business Integrity:A Toolkit for Medium-Sized Enterprises4Executive summaryEstablishing and maintaining business integrity is a complex challenge,even for large

23、corporations with significant resources and specialized expertise.For medium-sized companies,the obstacles differbut are no less significant,especially given the widespread nature of corruption.Small-and medium-sized enterprises(SMEs)often lack the resources to develop comprehensive anti-corruption

24、measures,making them particularly vulnerable.To address these challenges,a proactive,well-defined,and comprehensive strategy that empowers decision-makers at all levels of the business is recommended.This report provides a step-by-step,practical and simplified toolkit for SMEs to create a culture of

25、 integrity.It includes:1 The business case for integrity:An overview of how integrity can enhance business performance and mitigate risks associated with corruption.2 Create the foundation:Approaches for building an ethics committee and the tools and methodologies to identify,evaluate and manage cor

26、ruption risks within your business operations.3 Draft anti-corruption policy:A template to help your SME develop a robust anti-corruption policy tailored to your business needs.4 Financial crimes clause:Guidance on incorporating financial crime prevention measures into your contracts and agreements.

27、5 Conflict of interest framework:Strategies to identify and manage conflicts of interest,ensuring decisions are made in the best interest of the business.6 Complaints handling framework:A systematic approach to handling complaints,ensuring transparency and accountability within your business.By impl

28、ementing these components,your business can build a resilient framework to combat corruption.This not only safeguards your business against the risks associated with corruption but also enhances your reputation,facilitates trust with stakeholders and ultimately contributes to long-term success.You a

29、re encouraged to use this toolkit as a foundation to develop and strengthen your business integrity initiatives.SMEs face significant challenges in maintaining business integrity,but they can make the most impactful contribution to fight corruption.Business Integrity:A Toolkit for Medium-Sized Enter

30、prises5IntroductionThis toolkit developed by Transparency International and the World Economic Forum,in collaboration with key global good governance and anti-corruption champions,aims to become a reference for SMEs,helping them clearly understand the key benefits of business integrity.It explains t

31、he main terms and concepts integral to anti-corruption and provides some key examples of how the various aspects manifest themselves in practice.With corruption prevalent across all regions,practical solutions are critical to supporting the upskilling of representatives at the forefront of trade and

32、 business.Why business integrity matters for SMEsTrust is fundamental to all levels of business transactions,from individual dealings to international trade agreements.Business integrity facilitates trust by ensuring transparency,honesty,reliability and ethical behaviour.Similar to other aspects of

33、a business,trust is built through conscious efforts and trust-building programmes integrated into the wider business strategy.Trust plays a crucial role in enhancing a companys reputation.Companies known for their integrity are more likely to gain the trust of customers,investors,suppliers and partn

34、ers.This strong reputation reduces perceived risks for stakeholders,encouraging more business interactions.For example,if buyers trust a supplier to deliver quality goods or services,they are more likely to engage in frequent and larger transactions due to the certainty that their expectations will

35、be met.Trust also helps lower transaction costs.Although robust due diligence measures are always recommended when entering into new commercial relationships,if there is a higher risk or the potential does not demonstrate high business integrity standards,the due diligence process becomes more exten

36、sive,which in turn increases time and cost.Lastly,trust enhances the security and quality of products and services,increasing consumer confidence and loyalty.Reliability is critical,whether in business-to-customer(B2C)or business-to-business(B2B)interactions.Strategic benefits of business integrityF

37、ocusing on business integrity offers several strategic benefits to small-and medium-sized enterprises(SMEs).Notably,it can create opportunities across some key drivers of business success:Competitive advantage:Companies known for their integrity stand out in the marketplace.This reputation attracts

38、more loyal customers and creates additional business opportunities.Companies implementing anti-corruption programmes and robust ethical guidelines experience significantly fewer incidents of corruption up to 50%less compared to those lacking such initiatives.1 Therefore,these steps mitigate potentia

39、l losses associated with corruption.Customer loyalty:Ethical practices build trust,leading to greater customer loyalty.Customers are more likely to stay with and recommend companies they trust.Todays customers are well-informed and increasingly prioritize ethical considerations.They prefer to buy fr

40、om reliable and ethical companies,and while price and quality were once the main factors in purchasing decisions,now factors like sustainability,human rights and community engagement are highly relevant for both consumers and businesses.Employee morale and retention:Employees increasingly prefer to

41、work for companies with strong ethical standards,which in turn boosts morale,productivity and retention rates.Regulatory compliance:Companies with strong integrity practices are better at complying with regulations and experience fewer regulatory hurdles when entering new markets.This helps them avo

42、id legal penalties and enhances their standing with regulators.There is a growing trend of regulating the supply chain of large companies.This means that SMEs should be prepared to comply with new and diverse regulatory requirements,to attract and win business opportunities.Business integrity is cru

43、cial for SMEs as it builds trust,reduces risks,provides a competitive advantage,and helps integrate into global supply chains.Companies with strong integrity practices are better at complying with regulations and experience fewer regulatory hurdles when entering new markets.Business Integrity:A Tool

44、kit for Medium-Sized Enterprises6Long-term sustainability:Integrity-driven companies proactively identify potential quality issues at an earlier stage due to risk management efforts.Such risks can range from internal fraud and employment practices that enable unethical behaviours to business financi

45、ng and high-risk customer approaches,such as organized crime and illegal trading.Companies committed to high ethical standards often have better quality controls.This ensures that their products and services consistently meet rigorous quality requirements.They implement robust solutions and continua

46、lly refine their processes,leading to increased product safety and reliability.Investment attraction:Investors are more inclined to fund companies with transparent and ethical practices.These companies are seen as lower risk and potentially offer higher returns.Investors are increasingly prioritizin

47、g companies with strong ethical standards,recognizing that such companies are less likely to be involved in scandals,legal issues or financial misreporting that could jeopardize their investments.According to Transparency International UK,2 integrity in business practices cultivates transparency,acc

48、ountability and ethical behaviour,which are essential for building a sustainable and resilient business model.Companies that consistently demonstrate integrity tend to attract more investment as they present lower risk and higher potential for long-term value creation.3Five-year ethics premiumFIGURE

49、 15001000150020002019202020212022202320242024 ethics premium Global market all cap*Solactive GBS Global Markets All Cap USD Index TR Five-year ethics premium:12.3%The listed 2024 Worlds Most Ethical Companies Honorees outperformed a comparable index of global companies by 12.3 percentage points from

50、 January 2019 to January 2024.Source:Worlds Most Ethical Companies.For a company to be most attractive to investors,it must establish robust governance structures that promote transparency and accountability.This includes having a well-defined code of conduct,effective compliance programmes,and regu

51、lar and transparent reporting practices.Regular independent audits and active engagement with stakeholders,including shareholders,customers and employees,further enhance a companys credibility and attractiveness as an investment target.Stakeholder capitalism,which emphasizes considering the interest

52、s of all stakeholders including employees,customers,suppliers and the broader community,can significantly enhance a companys integrity and environmental,social and governance(ESG)performance.This approach not only mitigates risks associated with unethical practices but also aligns with the values of

53、 socially conscious investors,thereby increasing investment attractiveness.Companies that adopt stakeholder capitalism are better positioned to demonstrate strong governance,social responsibility and environmental stewardship,making them more appealing to investors seeking long-term value creation a

54、nd sustainability.Business Integrity:A Toolkit for Medium-Sized Enterprises7ESG considerations reflect a companys commitment to sustainable and responsible business practices,addressing issues such as environmental impact,social responsibility and governance quality.Firms that excel in these areas n

55、ot only mitigate risks associated with unethical practices but also align with the values of socially conscious investors.As such,companies that prioritize integrity and ESG factors are well-positioned to attract investment and build lasting relationships with banks and financial institutions.Govern

56、ance and integrity are the foundations for delivering on ESG goals,as corporate corruption has wide-ranging consequences.It is both a vertical and horizontal concern directly measurable as an important factor within the“G”of ESG,while simultaneously affecting the“S”and“E”.4ESG is also increasingly g

57、overned by mandatory disclosure requirements instead of the previous practice of voluntary standards.The European Unions Corporate Sustainability Reporting Directive(CSRD),in force since 2023,makes it compulsory for eligible companies to report on anti-corruption across their supply chains under the

58、 European Sustainability Reporting Standards(ESRS),specifically G1 on business conduct.Companies are expected to begin applying these new rules in their reports for the 2024 financial year,to be published in 2025,and cover corruption,bribery,political influence and lobbying.Additionally,there is now

59、 the Corporate Sustainability Due Diligence Directive(CSDDD),which reinforces these requirements by mandating that companies conduct due diligence to identify,prevent,mitigate and account for adverse human rights and environmental impacts in their operations and supply chains.Access to suppliers and

60、 new markets:Business integrity is critical for accessing new partnerships and new customers in local,regional and international markets.It becomes increasingly important as growth across markets is prioritized and where a companys reputation plays a larger role in forming new relationships critical

61、 for scaling.Companies driven by integrity are more likely to attract customers.Such companies are also more successful at entering new markets.Governments,regulatory bodies and customers often scrutinize the ethical practices of new businesses,for example,Germanys Supply Chain Act,Brazils Anti-Corr

62、uption Law(Federal Law.No.12,846/2013),Mexicos 2013 General Law of Administrative Responsibilities,2016 etc.Scaling through meaningful partnerships and collective action:Partnerships are another area where integrity-driven companies excel.Both public and private entities prefer to partner with compa

63、nies that share their high ethical standards.Meeting these standards can lead to significant business opportunities since integrity enables meaningful partnerships with multinational enterprises(MNEs)and other SMEs,allowing businesses to pool resources and scale operations effectively.Shared values

64、and goals are the bedrock of good partnership.Companies with similar ethical standards and values are more likely to align on their goals and strategies,making their partnerships more effective.Furthermore,integrity helps in risk mitigation.Partners feel more confident working with businesses that d

65、emonstrate integrity and have clear,ethical strategies,as this reduces the risk of fraud,corruption and other unethical practices.Collective action can further enhance the effectiveness of these partnerships.By joining forces with other businesses,industry associations and non-governmental organizat

66、ions,companies can address systemic issues such as corruption and unethical practices more effectively.Collective action promotes a collaborative approach to problem-solving,strengthens industry standards and amplifies the impact of individual efforts to maintain integrity.Companies driven by integr

67、ity are more likely to attract customers are also more successful at entering new markets.Business Integrity:A Toolkit for Medium-Sized Enterprises8Why business integrity should be a priority for owners and managers of SMEsTone from the top:Tone from the top refers to the ethical climate and culture

68、 set by an organizations senior management.It is crucial for several reasons:Firstly,senior leaders like owners,founders and chief executive officers set the standard for behaviour within the organization.Employees tend to emulate their leaders actions and attitudes.When leaders“practice what they p

69、reach”,it encourages a culture of integrity,accountability and compliance throughout the organization.Employees are more likely to be engaged,motivated and loyal when they see their leaders as ethical and trustworthy.A positive tone from the top creates a healthy work environment,reducing turnover a

70、nd attracting top talent.Research indicates that ethical leadership,behavioural nudging and,to some extent,anti-corruption messaging can help to reduce corruption in certain settings.5Secondly,companies with a strong ethical tone from the top are more likely to earn and maintain the trust of externa

71、l stakeholders,including customers,investors and regulators.Lastly,a strong tone from the top helps in identifying,managing and mitigating risks associated with unethical behaviour and compliance violations.Itcan prevent scandals,legal issues and financial losses resulting from unethical practices.R

72、ole of personal liability:Personal liability of senior executives and board members plays a significant role in emphasizing the need for a strong tone from the top for the following reasons:1.Legal accountability:Executives and directors can be held personally liable for the actions of the company,p

73、articularly in cases of fraud,regulatory violations or negligence.2.Regulatory compliance:Regulations such as the US Sarbanes-Oxley Act(SOX),the US Foreign Corrupt Practices Act(FCPA)and the UK Bribery Act impose stringent requirements on companies to maintain accurate financial reporting and preven

74、t corruption.This applies to third-party practices,meaning eligible companies have to monitor and be comfortable with the anti-corruption practices of their suppliers,even those located outside of the US and UK,respectively.Senior leaders are often required to certify the accuracy of financial state

75、ments and the effectiveness of internal controls,thereby reinforcing the importance of a strong ethical tone.3.Reputation:The potential for personal financial loss,reputational damage and legal consequences acts as a deterrent against unethical behaviour.The next section provides an overview of the

76、main anti-corruption concepts relevant to business leaders and owners of SMEs.It defines and explains key terms and provides real-life scenarios that companies commonly encounter.Business Integrity:A Toolkit for Medium-Sized Enterprises9Anti-corruption and bribery risks1Corruption comes in multiple

77、forms,and the difference between acceptable business practice and corrupt practice is usually purpose or intention.Corruption is the abuse of entrusted power for private gain.6 Anti-corruption,on the other hand,refers to a set of policies,practices and measures aimed at preventing,detecting and addr

78、essing corruption in all its forms within organizations,governments and societies.It encompasses a comprehensive approach to promote transparency,accountability and integrity in the public and private sectors.Bribery is the act of offering,giving,receiving or soliciting something of value to influen

79、ce the actions of an individual in a position of power or authority.It is a specific form of corruption and includes both active bribery,that is,the act of offering or giving a bribe and passive bribery,that is,the act of receiving or soliciting a bribe.While bribery is a big part of corruption,it i

80、s not limited to bribery.In reality,there are different forms of corruption,as outlined in the following sections.Usually,the difference between an acceptable business practice and a corrupt practice is the purpose or intention of an act.Conceptual frameworkThe conceptual framework for anti-corrupti

81、on and bribery involves several interconnected principles and components as recommended by Transparency International:1.Integrity and accountability:Integrity:Establish a culture of integrity where ethical behaviour is promoted and valued across all levels of the organization,where the tone from the

82、 top establishes clear expectations.Accountability:Ensure that individuals and institutions are accountable for their actions and decisions.This includes clear mechanisms for reporting,auditing and sanctioning corrupt activities.2.Transparency:Open governance:Implement policies that ensure transpare

83、ncy in decision-making processes and access to information.Public disclosure:Mandating the disclosure of assets,incomes,and potential conflicts of interest by public officials and private sector leaders.3.Participation:Civil society engagement:Encourage active participation of civil society organiza

84、tions,media and the general public in anti-corruption efforts.Stakeholder involvement:Involve various stakeholders in the development and implementation of anti-corruption policies.4.Rule of law:Legal framework:Establish and enforce robust legal frameworks that criminalize all forms of bribery and c

85、orruption.Judicial independence:Ensure an independent judiciary capable of impartially adjudicating cases of corruption.5.Preventive measures:Risk assessments:Conduct regular corruption risk assessments to identify and mitigate potential vulnerabilities.Business Integrity:A Toolkit for Medium-Sized

86、Enterprises10 Training and education:Provide continuous education and training to public officials,employees and other stakeholders on anti-corruption measures and ethical standards.6.Detection and reporting:Whistleblower protections:Implement strong whistleblower protection laws.Monitoring and audi

87、ts:Establish independent monitoring and auditing bodies to oversee the implementation of anti-corruption policies and practices.7.Enforcement:Investigations and prosecutions:Ensure thorough and impartial investigations of corruption cases and hold perpetrators accountable through appropriate legal a

88、ctions.Sanctions:Imposing effective,proportionate and dissuasive sanctions against those involved in corruption,including fines,imprisonment and bans from holding public office.8.International cooperation:Cross-border collaboration:Promote international cooperation and mutual legal assistance in inv

89、estigating and prosecuting transnational corruption and bribery.Global standards:Adopt and adhere to international anti-corruption conventions and standards,such as the United Nations Convention against Corruption(UNCAC)and the Organisation for Economic Co-operation and Development(OECD)Anti-Bribery

90、 Convention.Multistakeholder initiatives:Encourage collaboration among business,government and civil society to collectively address corruption,including industry-specific collective action where companies within the same sector work together to establish anti-corruption standards and practices.Busi

91、ness Integrity:A Toolkit for Medium-Sized Enterprises11Business Integrity:A Toolkit for Medium-Sized Enterprises11Gifts,hospitality and entertainment:good vs bad practiceFIGURE 2Bad practiceThe person in charge of the procurement in company A offers to award a service to a supplier in exchange for a

92、 certain gift or personal award.Good practiceCompany B can give and receive gifts valued at up to$50 without influencing the workers decision-making.If the gifts exceeds$50,it must be returned.Note:This$50 limit may not apply in all situations,particularly with public sector officials.In the case of

93、 public sector officials,no amount should be offered or accepted.1.1 Application in practiceImplementing this conceptual framework requires a multifaceted approach involving various sectors and levels of society.For instance:Governments can establish anti-corruption regulations and agencies,develop

94、national anti-corruption strategies and ensure transparency in public procurement.Businesses and industry associations should adopt corporate codes of conduct,conduct due diligence and implement internal controls to prevent,detect and address bribery.Civil society,non-governmental organizations and

95、media should advocate for policy reforms,monitor government actions and raise public awareness about the detrimental effects of corruption.By integrating these principles and components,societies can build robust systems to combat corruption and bribery,ultimately promoting a culture of integrity an

96、d good governance.Together,change is possible even in situations where corruption is deeply embedded.To achieve this,it is important to establish a common understanding of corrupt practices.The following section defines key terms explaining different and common types of corruption and bribery that b

97、usinesses encounter.It then provides illustrations of good practices as well as bad practices to help SMEs understand the differentiating line between corrupt practice and non-corrupt practice.1.Gifts,hospitality and entertainmentOffering an expensive gift,lavish hospitality or entertainment may be

98、perceived as bribery,depending on local laws.In practice,these can be used as a more subtle form of bribery than cash if there is an intention of inappropriately gaining a commercial advantage.Sometimes,this is also a means to pave the way for a larger bribe.Gifts,and reasonable hospitality and ente

99、rtainment offered in the course of business for the purpose of building good relationships and marking special occasions do not constitute bribes.Therefore,it is important to understand the difference.To protect your company and the people you work with,it is important to understand and develop a po

100、licy on the circumstances in which gifts and hospitality can be given or accepted,and what records should be kept of them.7 Make sure your business partners know your rules.Business Integrity:A Toolkit for Medium-Sized Enterprises12Conflict of interest:good vs bad practiceFIGURE 3Bad practiceThe bro

101、ther of company As executive director enters the company without going through the ordinary recruitment process.Such a conflict of interest is not reported or evaluated internally.Good practiceA relative of company Bs director emerges as the top candidate to hold a position in the same company durin

102、g a competitive recruitment process.This is reported,and it is internally evaluated whether the position they will hold could cause a conflict of interest.Bribes can be disguised as charitable contributions or sponsorships.9 Make sure that the money your company pays to a charity is not dependent on

103、 a commercial agreement or used to obtain a contract or do business.Always give that money to the organization,not to a person.Sponsorship refers to the payments made by the company,in cash or in kind,to link its name to an event(e.g.a sporting activity)or relate to a well-known person(e.g.a singer)

104、.The legitimate benefit for the company is that its name is associated with what is known and famous,but the sponsorship must offer real and measurable benefits for the company,such as generating publicity or greater brand strength.Make sure the sponsorship is for the benefit of the company and is n

105、ot used to cover up bribery.Social investment refers to the contribution of skills and/or resources to a host society to provide lasting benefit to the host society and/or the environment and to the company making it.Activities may range from increasing local capacity-building skills to supporting n

106、ational education,health,or conservation programs.Social Investment may be voluntary or required by a host government under a contract.Conflicts of interest arise when the various interests,duties or commitments that a person may have;family,friends,work,voluntary work or political interests,come in

107、to conflict(or are very likely to).8These conflicts can taint peoples judgment and lead to actions that are neither honest nor transparent.This can sometimes lead to a situation where people act against their better judgment and give or accept a benefit that can harm your company.Clear rules must be

108、 established for handling potential conflicts of interest.Even without professional negligence,conflicts of interest can be perceived as corrupt activities,causing significant damage to the companys reputation.2.Conflict of interest3.Charitable donations,sponsorships and social investmentsBusiness I

109、ntegrity:A Toolkit for Medium-Sized Enterprises13Charitable donations and sponsorship:good vs bad practiceFIGURE 4Company B sponsors a sports organization solely for brand promotion at an event.To ensure proper execution,the company secures backups,such as a contract.These sponsorships often include

110、 event access,which company B considers hospitality when offered to clients,partners,vendors,etc.Good practiceCompany A makes a charitable contribution to a foundation whose owner is a public servant on whom the award of a contract for company A depends.Bad practiceFacilitation payments can be seen

111、as a form of bribery and are,as such,illegal in many countries.These may be small amounts required by service providers to guarantee or“facilitate”the services to which you or your company are entitled,10 such as connecting a telephone or obtaining a visa,or money offered to customs,immigration or o

112、ther officials to“speed up”the provision of services and the granting of permits.Unfortunately,these payments are so common in many countries that they are considered“normal”or“inevitable”,even though they are often illegal and,therefore,can and should be avoided.Being clear about how you can ensure

113、 you do not make facilitation payments will help you and your partners deal with this problem.Facilitation payments and bribes:good vs bad practiceFIGURE 5For each disbursement generated for procedures,company B fills out internal control sheets that are supported with an invoice or proof of payment

114、.Good practiceCompany A makes a payment to the personal account of a public servant to speed up obtaining an authorization that usually takes three times as long.Bad practice4.Facilitation payments and bribesBusiness Integrity:A Toolkit for Medium-Sized Enterprises14Bribes can be disguised as politi

115、cal contributions.If your company wishes to make a contribution to a political party or candidate,it is important to ensure that it complies with national law and,if allowed,that this decision is made openly and does not have an expectation of return.If you have a Board of Directors,that decision sh

116、ould be recorded as a Board resolution.If it does not,the plan to make the donation must be noted at a management meeting.Ensure that everyone in the organization knows about the decision to make a political contribution on behalf of the company.The decision should be made with the consensus of seni

117、or company executives or the board,and should never be made by a single person without the knowledge and consent of management.Pay attention to the opportunity and timing of making such a contribution.If you are in the middle of a negotiation process to obtain a contract or a government licence,for

118、example,a planning permit,or if a sensitive issue in your business is being examined by the government,contributions to the government or a local political party could be seen as a bribe.The contribution should also be recorded in the accounting books of your company through the financial system if

119、it is made in cash,and the beneficial owners of the company should be disclosed to the political party or candidate,so they can weigh in on its acceptance.Political contributions are extremely sensitive and should be avoided as much as possible.If you choose to make one,its purpose will determine it

120、s legality.11Political contributions:good vs bad practiceFIGURE 6Bad practiceCompany A makes a contribution to a political campaign of a future mayor,in order to obtain permission to build a factory in an area where building is not permitted.Good practiceCompany B is committed to transparency and op

121、enly states its stance as an apolitical company.Whenever it chooses to make a political contribution,the company informs its stakeholders of each financial contribution,its purpose and documents the details of every contribution.Any favour to public officials or business partner may be easily percei

122、ved as bribery,leading to severe legal and reputational consequences for the company.It is advisable to avoid granting favours to public officials and business partners,especially when there is an ongoing commercial relationship.Such favour can undermine public trust and compromise the integrity of

123、both the company andthe officials or partners involved.5.Political contributions6.FavoursBusiness Integrity:A Toolkit for Medium-Sized Enterprises15Favours:good vs bad practiceFIGURE 7Good practiceAn executive at company B learns that a public official is facing a personal tax issue.The executive of

124、fers to introduce them to a highly reputable tax consultant with the applicable authorization from all involved stakeholders,ensuring transparency.The public official is not involved with the company on an ongoing basis.An executive at company A learns that a public official conducting inspections a

125、t the company is facing a personal tax issue.The executive offers to introduce them to a highly reputable tax consultant who can provide expert advice at a discounted rate and help resolve the issue.Bad practiceLobbying activities can be perceived as a way to influence and inform governments and is

126、a legitimate aspect of the democratic process.12 However,if performed unethically,lobbying may involve undue political influence and corruption at the expense of the public interest.It is essential that the company determines the guidelines for lobbying activities to ensure that they do not amount t

127、o corrupt practices.It is critical to ensure transparency and oversight by senior leadership and to align lobbying activities with social and environmental commitments.Lobbying:good vs bad practiceFIGURE 8Good practiceIndividuals from company B provide useful corporate information and contributions

128、to politicians to assist in drafting relevant societal policies,and make appropriate disclosures of their interactions.Company A offers incentives to political agents to influence their political decisions.Bad practice7.LobbyingBusiness Integrity:A Toolkit for Medium-Sized Enterprises16Third-party e

129、nablers:good vs bad practiceFIGURE 9Third parties and intermediaries,in particular,are the single greatest area of bribery risks for companies.These risks are increasing as companies move into new markets and put ever more of their operations in the hands of third parties.Intermediaries such as advi

130、sers,forwarding agents,brokers and lawyers can sometimes facilitate corruption.For example,a state-owned company or government body might recommend a specific law firm or consulting company as an adviser for services,often with high fees.If there is no strong business reason to hire these advisers,i

131、t could indicate a potential channel for corruption.13Good practiceCompany B and its contracting partners each select their own advisers,agents and lawyers based on their specific needs and has demonstrated ethical business practices.The company remains cautious of forwarding agents who can achieve

132、results that others cannot.A public servant requires company A to hire specific advisers,forwarding agents or lawyers to provide their services.Bad practice8.Third-party enablers(consulting companies,brokers,agents and lawyers)Business Integrity:A Toolkit for Medium-Sized Enterprises17Business Integ

133、rity:A Toolkit for Medium-Sized Enterprises17Business associations:good vs bad practiceFIGURE 10Company A turns a blind eye to something that may not be strictly correct in terms of lobbying,events and other relationships with government bodies.Company B questions decisions and is attentive to certa

134、in“wins”during discussions with the government.It questions intermediaries,advisers and lawyers that the association has hired.Good practiceBad practiceTrades of commerce and associations may also be used as a channel for corruption.Lobbying is often done through such associations,particularly when

135、the subject-matter of lobbying contradicts the explicitly stated position or lobbying aims of the company,for instance,a companys position on climate-related issues.14 Business associations may also use the company funds or resources(e.g.membership fee),either directly or indirectly,to help fund pol

136、itical campaigns,political parties,political candidates,or anyone associated with them.If you participate in such associations,be attentive,participate in meetings as much as possible,question decisions,sponsorships and relationships.In case of any doubt on legal and ethical implications,it is advis

137、able to seek guidance from an expert adviser.9.Business associationsBusiness Integrity:A Toolkit for Medium-Sized Enterprises18Create the foundation2Foundational steps for building an SME business integrity programme are creating an ethics committee and conducting a risk assessment.The ethics commit

138、tee(may also be called compliance committee)is a dedicated group within the company responsible for ensuring compliance with regulations and internal policies.It consists of representatives from various areas who work together to manage compliance risks,develop programmes,provide guidance and traini

139、ng,and promote a culture of integrity.The committee helps maintain transparency,accountability and good governance practices.Establishing a permanent internal ethics or compliance committee brings numerous benefits to SMEs.It enables effective handling of internal discussions and decision-making pro

140、cesses,especially when dealing with the application of the anti-corruption policy,findings from risk assessments and cases arising from whistleblowing channels(see section 3.3).By having a dedicated committee,SMEs can ensure compliance with anti-corruption strategies and create a culture of integrit

141、y within the organization.Suggested roles and responsibilitiesTo form a successful ethics committee,consider including the following individuals.Each SME can,however,adapt the committee according to its specific needs and structure.Chief executive officer or management representative:This role provi

142、des overall guidance and leadership to the committee.Human resources(HR)representative:Responsible for ensuring compliance with employment laws,regulations and policies,including training.Legal representative:Provides legal guidance and ensures compliance with applicable laws and regulations.Finance

143、 representative:Oversees financial compliance,including anti-corruption measures and reporting.Operations representative:Ensures compliance in day-to-day operations,including supply chain and vendor management.IT representative:Manages data privacy and cybersecurity compliance.Representation from va

144、rious areas of the organization can help ensure that the SME operates with integrity,adheres to laws and regulations,and maintains a strong ethical culture.Having the chief executive officer lead the committee demonstrates commitment to compliance and ethics,prioritizing these efforts and integratin

145、g them into the SMEs overall strategic direction and goals.An SME can choose to incorporate the rules of operation of the ethics committee either within the anti-corruption policy or through separate guidelines,using the model template below.15 Template for ethics committeeCompany Name Ethics commit

146、tee guidelines1.Purpose:Clearly state the purpose of the committee,emphasizing its role in ensuring compliance with laws,regulations and internal policies and its responsibility in promoting a culture of integrity and ethical behaviour within the organization.2.Composition:Specify the members of the

147、 committee,including their roles and responsibilities.3.Meetings and reporting:Outline the frequency and format of committee meetings.Establish reporting mechanisms for committee activities.By having a dedicated committee,SMEs can ensure compliance with anti-corruption strategies and create a cultur

148、e of integrity within the organization.2.1 Ethics committeeBusiness Integrity:A Toolkit for Medium-Sized Enterprises194.Responsibilities:Detail the specific responsibilities of the committee,such as:Conduct corruption risk assessments Handle whistleblowing reports,conflict of interest reports and in

149、vestigations Develop and implement anti-corruption policies,compliance programmes and policies Monitor compliance activities and address any identified issues Provide guidance and training to employees on compliance and anti-corruption matters Collaborate with relevant departments to ensure business

150、 integrity in their respective areas5.Decision-making and authority:Clarify the decision-making process within the committee,including voting procedures and the role of the committee leader Specify the authority of the ethics committee in making recommendations or taking actions related to complianc

151、e matters6.Confidentiality and conflict of interest:Emphasize the importance of maintaining confidentiality regarding committee discussions and sensitive information Address potential conflicts of interest(see chapter 5)and establish guidelines for committee members to disclose any conflictsMapping

152、potential corruption scenarios allows your company to proactively assess situations that could negatively impact your business.The risk assessment exercise is essential for understanding your businesss specific needs and potential risks.It also helps to recognize improvement opportunities and emphas

153、izes the companys commitment to fighting corruption and implementing best practices on business integrity.Implementation tips Where possible,establish a cross-functional risk management team that provides context on various aspects of risk.Define a representative who is responsible for convening a g

154、roup,that is,the ethics committee,with members from different business functions to inform and regularly update the risk assessment.Once a risk assessment is conducted,the ethics committee should define specific prevention actions.The ethics committee should monitor the occurrence of the different a

155、nti-corruption scenarios listed in chapter 1 and update the toolkit annually.The risk assessment matrix in Table 1 provides a practical tool for identifying typical situations where there is a risk of corruption.Assessing the likelihood of occurrence and the potential reputational impact can help id

156、entify potential corruption situations and determine which preventive actions should be taken to mitigate any impact on your company.The full risk assessment matrix can be downloaded here.2.2 Risk assessment frameworkBusiness Integrity:A Toolkit for Medium-Sized Enterprises20Business Integrity:A Too

157、lkit for Medium-Sized Enterprises20MatrixTABLE 1Risk assessment analysis(1)What is it?This matrix identifies corruption-related risks and defines preventative actions to mitigate impact on your company.(2)What are its benefits?This matrix benefits yourcompany by enabling the development of a tailore

158、d action plan,promoting teamwork and demonstrating commitment to fighting corruption.(3)How to implement it?Please fill in the fields highlighted in grey,following the instructions provided in green.For that,collaborate with the different areas of your company to(1)identify specific risks,(2)define

159、prevention actions and(3)monitor and update the tool annually.Company name:Main problems associated with corruptionGuiding questions to understand each main problem associated with corruption1Possible impact area2 Comments3 Impact on the organization4 Probability of occurrenceResultsImpact on the or

160、ganizationProbability of occurrenceResultsGifts and hospitalityAre gifts and hospitality frequently offered or received in your business operations?Are there any policies or guidelines in place regarding the acceptance of gifts and hospitality?How transparent and accountable is the process of record

161、ing and reporting gifts and hospitality?Note:consider that offering an expensive gift,lavish hospitality or entertainment may be perceived as bribery depending on local laws.Medium likelihoodLow likelihoodConflict of interestAre there mechanisms in place to identify and manage conflicts of interest

162、within your organization?How are conflicts of interest disclosed and addressed?Are employees aware of their obligation to report potential conflicts of interest?Note:a conflict of interest arises when a personal interest or relationship is placed before the interests of the company.These conflicts c

163、an taint peoples judgment and lead to actions that are neither honest nor transparent.Medium likelihoodMedium likelihoodCharitable contributions and sponsorshipsHow are charitable contributions and sponsorships selected and approved?Are there any criteria or guidelines in place for evaluating potent

164、ial recipients?How transparent and accountable is the process of reviewing and monitoring charitable contributions and sponsorships?Note:bribes can be disguised in the form of charitable contributions or sponsorships.The difference between an acceptable business practice and a hidden bribery practic

165、e is the purpose or intention of the contribution.High likelihoodHigh likelihood1 1 Action 1:Identify the specific activities or areas within your operation where each main problem associated with corruption may occur and provide a brief reference for each.2 Action 2:Provide any insights that may be

166、 useful in developing action plans to prevent each main problem associated with corruption from occurring in your company.Make connections with the available resources in the toolkit.3 Action 3:Provide any insights that may be useful in developing action plans to prevent each main problem associated

167、 with corruption from occur-ring in your company.Make connections with the available resources in the toolkit.4 Action 4:Provide any insights that may be useful in developing action plans to prevent each main problem associated with corruption from occurring in your company.Make connections with the

168、 available resources in the toolkit.Risk assessment analysis(1)What is it?This matrix identifies corruption-related risks and defines preventative actions to mitigate impact on your company.(2)What are its benefits?This matrix benefits yourcompany by enabling the development of a tailored action pla

169、n,promoting teamwork and demonstrating commitment to fighting corruption.(3)How to implement it?Please fill in the fields highlighted in grey,following the instructions provided in green.For that,collaborate with the different areas of your company to(1)identify specific risks,(2)define prevention a

170、ctions and(3)monitor and update the tool annually.Company name:Main problems associated with corruptionGuiding questions to understand each main problem associated with corruption1Possible impact area2 Comments3Impact on the organization4 Probability of occurrenceResultsImpact on the organizationPro

171、bability of occurrenceResultsFacilitation payments (irregular payments to government official or individual in a position of power to expedite or facilitate routine administrative actions or services that are within their official duties)Are employees aware of the companys stance on facilitation pay

172、ments?Are there measures in place to prevent facilitation payments and address facilitation payments request from others?How are facilitation payments requests,if any,recorded and reported?Note:facilitation payments is a form of bribery and,as such,illegal in almost all countries.These may be small

173、amounts required by service providers in order to guarantee or facilitate the services to which you or your company are entitled to speed up the provision of services and the granting of permitsLow likelihoodLow likelihoodPolitical contributionsIs the company engaged in providing political contribut

174、ions?If yes,are there policies or guidelines regarding political contributions?How are political contributions reviewed and approved?Are there any legal or regulatory restrictions on political contributions in your country?Note:bribes can be disguised as political contributions.If your company wishe

175、s to make a contribution to a political party or political candidate,it is important to ensure that it complies with the national law and,if allowed,that this decision is made openly and does not have an expectation of return.High likelihoodMedium likelihoodLobbyingIs the company engaged in lobbying

176、 activities?If yes,are there any policies or guidelines regarding lobbying activities?How are lobbying activities reviewed and approved?Are there any legal or regulatory requirements for lobbying in your country?Note:lobbying activities can be perceived as a way to influence and inform governments a

177、nd is a legitimate tool for influencing public policies.However,if not performed ethically,lobbying may involve political influence and corruption at the expense of the public interest.Medium likelihoodMedium likelihood1 Action 1:Identify the specific activities or areas within your operation where

178、each main problem associated with corruption may occur and provide a brief reference for each.2 Action 2:Provide any insights that may be useful in developing action plans to prevent each main problem associated with corruption from occurring in your company.Make connections with the available resou

179、rces in the toolkit.3 Action 3:Provide any insights that may be useful in developing action plans to prevent each main problem associated with corruption from occurring in your company.Make connections with the available resources in the toolkit.4 Action 4:Provide any insights that may be useful in

180、developing action plans to prevent each main problem associated with corruption from occurring in your company.Make connections with the available resources in the toolkit.Risk assessment analysis(1)What is it?This matrix identifies corruption-related risks and defines preventative actions to mitiga

181、te impact on your company.(2)What are its benefits?This matrix benefits yourcompany by enabling the development of a tailored action plan,promoting teamwork and demonstrating commitment to fighting corruption.(3)How to implement it?Please fill in the fields highlighted in grey,following the instruct

182、ions provided in green.For that,collaborate with the different areas of your company to(1)identify specific risks,(2)define prevention actions and(3)monitor and update the tool annually.Company name:Main problems associated with corruptionGuiding questions to understand each main problem associated

183、with corruption1Possible impact area2 Comments3 Impact on the organization4 Probability of occurrenceResultsImpact on the organizationProbability of occurrenceResultsAbsence of anti-bribery policyIs there a written anti-bribery policy in place?How is the anti-bribery policy communicated and enforced

184、 within the organization?Are employees aware of the policy and their obligations under it?High likelihoodMedium likelihoodAbsence of internal whistleblowing channelsAre there safe and confidential mechanisms for employees to report suspected bribery or corruption internally?How are whistleblowing re

185、ports handled and investigated?Are employees aware of the whistleblowing channels and their confidentiality?Note:robust internal whistleblowing channel encourages employees to report wrongdoing.Handle reports with care,ensuring confidentiality,presumption of innocence and no retaliation against whis

186、tleblowers acting in good faith.Low likelihoodLow likelihoodAbsence of ethical or compliance committeeIs there an established ethical or compliance committee within the company?Is the committee actively promoting business integrity and leading by example?Note:the ethics committee,led by the chief ex

187、ecutive officer,is a dedicated group of individuals responsible for ensuring compliance,managing risks,and promoting integrity within the company,benefiting SMEs by enhancing decision-making and fostering a culture of integrity.Medium likelihoodMedium likelihood1 Action 1:Identify the specific activ

188、ities or areas within your operation where each main problem associated with corruption may occur and provide a brief reference for each.2 Action 2:Provide any insights that may be useful in developing action plans to prevent each main problem associated with corruption from occurring in your compan

189、y.Make connections with the available resources in the toolkit.3 Action 3:Provide any insights that may be useful in developing action plans to prevent each main problem associated with corruption from occurring in your company.Make connections with the available resources in the toolkit.4 Action 4:

190、Provide any insights that may be useful in developing action plans to prevent each main problem associated with corruption from occurring in your company.Make connections with the available resources in the toolkit.Anti-corruption policy3This policy demonstrates an SMEs commitment to integrity and t

191、he core principles,values and business vision on integrity,compliance and the fight against corruption.Communicate commitment:An anti-corruption policy is the first step in manifesting an organizations strong commitment to integrity.It communicates a proactive approach and values to employees,third

192、parties and other stakeholders.Establish a culture of integrity:The policy enables your organization to understand its environment and main risks,as well as the values and principles that will guide your organization on the path to integrity.It also enables company executives or top officials to get

193、 involved and define their commitment to integrity and compliance.This demonstrates the“tone at the top”explained in chapter 1.It provides employees and third parties with certainty,protection and clarity regarding the companys ethical framework.Ensure compliance:The policy adds to an organizations

194、reputation and will give the business an advantage when working with large,global companies looking for suppliers.Global companies are subject to anti-corruption regulation across different jurisdictions,and an anti-corruption policy can help ensure that SMEs are proactive in implementing the rules.

195、It can also minimize risks to businesses,such as penalties and fines.Improve operational efficiency:The policy can serve as a basis for decision-making,while handling/preventing fraud improves efficiency.An anti-corruption policy adds to an organizations reputation and will give the business an adva

196、ntage when working with large,global companies.3.1 Benefits of an anti-corruption policyAn anti-corruption policy is integral to building trust and serves as the foundation for ethical business practices.It serves as the foundation for doing ethical business by developing a plan of action for a comp

197、any to practically implement business integrity,including anti-corruption practices.It is also the second step towards protecting your business,based on the risk assessment done by the ethics committee.Record:The decision to develop this policy must be recorded in writing.If the SME has a board of d

198、irectors,the proposal should be presented and agreed upon by a board resolution.If there is no board,management should come to a general agreement and maintain a book or file recording this decision.This is important to reflect intentions and protect the business in case of future allegations and ch

199、arges of corruption.The template in section 3.3 may be used to record your companys policy.Factor risks:It is important that every programme takes into account the context and risks that each company has identified,in accordance with the risk assessment framework in chapter 2.Communicate:Upon the in

200、corporation of this policy,it is necessary to communicate internally to employees through regular training and awareness sessions,as well as third parties such as distributors,agents,suppliers,contractors and buyers,emphasizing the importance of complying with the established principles,values and s

201、tandards.The policy should also be posted on the companys website,if there is one.While it is important that stewardship comes from the top of the organization,it is also critical that everyone within the organization takes individual responsibility for its implementation as part of the business str

202、ategy.3.2 Implementation tipsBusiness Integrity:A Toolkit for Medium-Sized Enterprises24The steps to socialize the policy with the business network include:1 Share the policy with all entities with whom the company has a business relationship,making it clear that the policy applies to those relation

203、ships.2 Ask each entity if they have a similar program in place,and if they do,request a copy of their policy.3 Include the policy in all contracts and agreements the company signs,with provisions for immediate termination if partners pay or accept bribes.A model clause is included in chapter 4.Allo

204、cate responsibility:It is essential to have someone internally responsible for monitoring policy compliance and periodically updating the policys content,as needed by the business.Good management and regular review can help identify irregularities with payments,gifts,entertainment,etc.Another critic

205、al step is developing a process for receiving and handling complaints through a complaint box mechanism.The ethics committee has overall responsibility and can allocate different roles to the different representatives on the committee.The following provides a template for a companys anti-corruption

206、policy.It should be amended to consider industry-and jurisdiction-related requirements.General principles We will not pay bribes or allow bribes to be offered on our behalf to gain a business advantage.We will not accept bribes or permit them to be accepted on our behalf to influence the company.We

207、will avoid doing business with those who do not share our values or may harm our reputation.We will ensure that everyone in our company,including our business partners,is aware of our anti-corruption principles.We will regularly review and update our programme and processes as needed.We will report

208、all acts of corruption and bribery or any serious suspicion of them to the relevant authorities.We will conduct our business activities fairly,honestly and transparently.We will conduct appropriate due diligence to know with whom we are doing business.We will uphold these principles even in challeng

209、ing situations.Gifts We may accept gifts in the form of small,low-value items.We may not accept high-value items.16 While occasional acceptance of a gift is allowed,we will not accept gifts offered on a regular basis.Gifts we give should not exceed the maximum value of X,comply with the law and be a

210、pproved by company management.17 Additionally,gifts must meet the following criteria:1)limited to reasonable and good faith expenses,2)do not unduly affect,nor be perceived as unduly affecting,the recipients judgment towards the giver,3)not contrary to the known provisions of the recipients code of

211、conduct,and 4)not offered or received too frequently or at an inappropriate time.Items of value received as gifts that go against the companys principles will be returned or disposed of as directed by company management.18 The company and its employees are aware that in cases where suppliers or thir

212、d-party service providers are compensated fairly and appropriately,no additional benefits or gifts should be provided.Hospitality We may offer and accept hospitality(or entertainment)with a host if it is reasonable and serves a legitimate business interest.3.3 Model anti-corruption policyBusiness In

213、tegrity:A Toolkit for Medium-Sized Enterprises25 We will not offer or accept extravagant or frequent hospitality,and we will not offer hospitality or entertainment without a host.19 Conflicts of interests20 A conflict of interest arises when a personal interest or relationship is placed before the i

214、nterests of the company.For instance,having a second job,having a relative who is a government official,having shares in another company.If any employee believes that a potential conflict of interest exists,they must report it to the Human Resources Director,Legal Director or Legal Representative so

215、 that the conflict of interest can be recorded and appropriate actions can be taken.This includes,but is not limited to,the disclosure of any existing or potential family business relationships that could influence or appear to influence any professional decisions or actions.Charitable contributions

216、 and sponsorship It is necessary to ensure that any money the company pays to a charitable entity is not contingent on a business agreement and is not made to secure a contract or conduct business.Sponsorship refers to cash or in-kind payments made by the company to associate its name with a popular

217、 event,such as a sports activity,or to associate with a well-known individual,such as a singer.The benefit to the company lies in linking its name to something well-known and famous,but sponsorship should offer real and measurable benefits to the company,such as increased publicity and brand strengt

218、h.Sponsorship should be conducted for the benefit of the company,which should be clear and measurable,and not to cover up a bribe.Facilitation payments Employees should reject all forms of facilitation payments as they constitute another form of bribery.Facilitation payments are understood as unoffi

219、cial and improper payments made to an official to ensure or expedite the performance of a routine or necessary action to which the payer of the facilitation payment is legally entitled.It may even involve small amounts demanded by service providers to guarantee or“facilitate”the services to which th

220、e company is entitled,such as connecting a phone or obtaining a visa,or itmay be money offered to a public official to illegally expedite the provision of services and the granting of permits.Political contributions21 Option one if you disagree with political contributions:Suggested text:This compan

221、y rejects all forms of political contributions.Option two if you agree with political contributions and it is legal in the country:This company may make political contributions.To do so requires approval of the board of directors/management,22 and must be internally recorded.The company commits to t

222、ransparently disclose all types of political contributions in its annual reports and publish them on its website if it has one.In any case,the decision to make a political contribution must consider the timing and must not be tied to any undue benefit.23 Additionally,the company commits to review th

223、e existing national regulations governing this matter.In other words,the purpose for which the contribution is made will be decisive in determining whether it constitutes a good practice or a covert bribe.Political contributions should be made only to registered organizations and never directly to a

224、n individual.Lobbying24 This company commits to ensuring any lobbying activity complies with applicable local,national and international laws,regulations and standards,such as the OECDs Recommendation of the Council on Transparency and Integrity in Lobbying and Influence.All lobbying activities must

225、 be approved in advance by the board of directors/management and must be internally recorded.Any lobbying activity must be conducted transparently and ethically,aligned to any public commitments on sustainable development,ensuring that all interactions with government officials are accurately docume

226、nted,publicly disclosed and reported as required by law.Business Integrity:A Toolkit for Medium-Sized Enterprises26Business Integrity:A Toolkit for Medium-Sized Enterprises26DisseminationThis policy must be internally disseminated and made freely accessible to all employees and relevant third partie

227、s who should be aware of it.25 It is recommended that both internal and external stakeholders of the company sign a statement confirming that they have received and understood the policy.The policy should be periodically disseminated to remind stakeholders at appropriate intervals and should be prom

228、ptly communicated to new stakeholders with whom the company establishes business relationships.Whistleblowing and reporting of possible violations This company prohibits any form of detrimental conduct,such as retaliation,discrimination or disciplinary measures,against anyone including employees and

229、 third parties who reports suspected wrongdoing in good faith or refuses to participate in wrongdoing,even if it results in a loss of business for the company.The company is responsible for following up on all such reports,including allowing anonymous reporting,investigating the reported incidents,t

230、aking corrective actions as appropriate,and informing the whistleblower of the findings and outcomes related to their report.Commitment The company agrees to implement this anti-corruption policy as a demonstration of its strong commitment to transparency and the fight against bribery in all its for

231、ms as a fundamental pillar of its corporate values.Business Integrity:A Toolkit for Medium-Sized Enterprises27Financial crime clauseBuild trust:Reflect values of integrity and transparency in your commercial relationships.This will help build trust in relationships with third parties.Prevent corrupt

232、ion:Require those who contract with your organization to make efforts to prevent and deter any type of corrupt activity and amplify your efforts.Reduce risks:Contribute to reducing legal,financial or reputational risks in your commercial relationships.A financial crime clause reflects the SMEs commi

233、tment to integrity and ensures contractors take necessary actions to prevent any type of corrupt activity.44.1 Benefits of a financial crime clause4.2 Implementation tipsIt is important to ensure that your commercial relationships with third parties have a contract.This will allow you to demand a mi

234、nimum level of service and compliance.The following clause is generic and applicable to all types of contracts that a company enters,including service contracts,sales contracts,etc.It is,however,important to note that for public contracts,there are specific regulations where incorporating clauses ma

235、y not always be permissible.Its essential to validate this on a case-by-case basis.In the absence of a contract,include this clause in purchase orders or as a standalone document when initiating a commercial relationship.Always clarify to your business relation that the purpose of the clause is to r

236、eaffirm the mutual commitment to integrity.4.3 Template for financial crime clause1.1 For purposes of this clause:1.1.1.“Financial crime”means criminal activities carried out by individuals or criminal organizations to provide economic benefits through illegal methods,including but not limited to fr

237、aud,drug trafficking,corruption and bribery,tax crimes,modern slavery and human trafficking,environmental crimes,smuggling illicit goods,money laundering,terror financing,cybercrime,illicit mining,and smuggling of precious goods.1.1.2.“Financial crime regulations”means laws,internal and external pol

238、icies and procedures,rules and requirements relating to international sanctions,prohibited business activities and the detection and prevention of money laundering and the financing of terrorism and includes but is not limited to list jurisdictions relevant to your company and other recognized extra

239、-territorial anti-corruption laws,including the US Foreign Corrupt Practices Act of 1977(FCPA)and the UK Bribery Actof 2010.1.1.3.“PEP/PIP”or“politically exposed person/prominent influential person”means any individual who is or has in the past been entrusted with government-related or other promine

240、nt functions in any country and encompasses the immediate family members and known close associates of such person.Business Integrity:A Toolkit for Medium-Sized Enterprises281.1.4.“Restricted party”means any person on a sanctions list and/or otherwise identified by financial crime regulations as a p

241、erson with whom trade or financial dealings are prohibited or restricted.1.1.5.“Sanctions list”means all mandatory and non-mandatory sanctions lists,including the sanctions lists of the United Nations Security Council,the United States Office of Foreign Assets Control,the United Kingdom Her Majesty

242、Treasury,the European Union and list jurisdictions relevant to your company.1.2 The service provider26 warrants,represents and undertakes the following:1.2.1.For the duration of this agreement,it will adhere to the highest levels of lawful,ethical and responsible business practices and all applicabl

243、e financial crime regulations.1.2.2.It will not commit any acts or engage in any activity,practice or conduct,whether directly or indirectly through the use of intermediaries(such as its affiliates,agents,consultants,advisers,resellers,distributors or business partners),which would constitute an off

244、ence under any applicable financial crime regulations.1.2.3.To its best knowledge and belief,neither it nor any principal,officer,employee,director or intermediary of the service provider1.2.3.1.Is a restricted party1.2.3.2.Is or has been subject to a conviction or charged with any financial crime,o

245、r the target or subject of any criminal investigation involving financial crime1.2.4.It shall not make,or authorize or tolerate to be made,in the performance of this agreement or otherwise,any payments,loans or gifts,or promises or offers of payments,loans or gifts,of any money or anything of value,

246、directly or indirectly,to or for the use or benefit of any person including without limitation to a PEP/PIP or the agencies or instrumentalities thereof.If the service provider knows or has reason to suspect that any payment or part of such payment,loan or gift will be,directly or indirectly,given o

247、r paid to any person,including a PEP/PIP or the agencies or instrumentalities thereof,the making of which would violate any applicable financial crime regulations.1.2.5.It will immediately report to the company any request or demand for any undue financial or other advantage of any kind received by

248、the service provider or its intermediaries in connection with the performance of this agreement.1.3 The service provider undertakes to notify the company immediately in the event that the undertakings referred to under this clause cease to be accurate.Business Integrity:A Toolkit for Medium-Sized En

249、terprises291.4 The service provider consents to the company undertaking the following:1.4.1.Auditing the service providers books and records relevant to the service providers account at any time with reasonable notice to ensure that the warranties,representations and undertakings set out in this cla

250、use are upheld by the service provider.1.4.2.Processing(including the monitoring,screening and disclosure)of the service providers information,including its personal information and special personal information to:1.4.2.1.Conduct screenings against sanctions lists.1.4.2.2.Monitor the service provide

251、rs instructions and transactions where necessary to ensure that the service provider complies with applicable financial crime regulations.1.4.2.3.Report any matches to sanctions lists or contraventions of applicable financial crime regulations to local and/or international regulatory authorities and

252、 affiliates of the company.1.5 If the company finds or reasonably believes that the service provider has breached or may be in breach of any of the provisions of this clause,the company will be entitled to immediately terminate the agreement without any liability to the company as a result of such t

253、ermination.1.6 The service provider will hold harmless and indemnify the company against any damage or loss,of whatever nature,suffered or incurred by the company as a result of termination of this agreement by the company under this clause.1.7 The service provider acknowledges and agrees that the c

254、ompany shall not be liable for any damage or loss,of whatever nature,suffered or incurred by the service provider as a result of the following:1.7.1.Processing by the company of the service providers personal information for purposes relating to financial crime regulations and screening against sanc

255、tions lists.1.7.2.Reporting of the service providers personal information to local and international regulatory authorities and affiliates of the company in the event that the service provider is matched to a sanctions list or found or reasonably believed to be in contravention of applicable financi

256、al crime regulations.Business Integrity:A Toolkit for Medium-Sized Enterprises30Conflict of interestPromote transparency:Establish open and transparent communication channels to promptly identify any potential situations that could affect your organization.This will promote a culture of compliance a

257、nd trust within your organization.Reduce risks:Take proactive actions to prevent potential conflicts of interest that could impact your organization.Inculcate impartiality:Encourage employees to develop impartial and objective attitudes and/or business relationships based on business needs.When pers

258、onal loyalties clash with company interests,clear rules and good judgment ensure an ethical and legally valid decision.55.1 Benefits of a conflict of interest formA conflict of interest can exist in any situation where loyalties may be divided between the companys interest and an individuals or betw

259、een the companys interests and those of anyone outside.The most clear-cut example of a potential conflict of interest arises from family ties.Naturally,there is interest in helping and supporting family,but this can be detrimental in certain circumstances(e.g.I am overseeing the bidding process for

260、a service,and one of the bidders is my father).These situations can hinder decision-making and harm the organization.Some even constitute acts of corruption,which is why it is important to identify and review such situations on a case-by-case basis.Most conflicts of interest can be avoided by follow

261、ing clear rules established by the company.Good judgment should be exercised to evaluate activities that may result in a conflict of interest,and any concerns about potential conflicts should be discussed with the companys management.Even the appearance of a conflict of interest can be problematic.C

262、onsider whether the situation would lead others to question the companys judgement,decisions or actions.The conflict of interest reporting form template(see section 5.3)aims to provide a practical tool to enable employees to promptly communicate potential situations that could be considered conflict

263、s of interest.The organization can then decide whether action should be taken to reduce any potential negative impact.Disseminate:Conduct organization-wide campaigns on an annual or biannual basis to encourage all employees to complete the form.This strategy can also be applied to new employees join

264、ing the organization.Analyse:Forms should be analysed by the human resources and legal teams,if available,to determine whether a potential conflict of interest exists and identify any necessary actions.It is important to inform the companys management about the results.Maintain confidentiality:Respo

265、nses should be treated confidentially,ensuring their proper management.Record:The obligation to complete this form should be reflected in the anti-corruption policy or other internal regulations of the organization.5.2 Implementation tipsBusiness Integrity:A Toolkit for Medium-Sized Enterprises315.3

266、 Template for conflict of interest formThis form aims to provide a reference tool for companies to proactively monitor and analyse potential conflict of interest events that could affect the company.DefinitionConflicts of interest arise when an individuals private interests or those of individuals c

267、lose to them differ from those of the organization to which the individual belongs.Conflicts of interest constitute a specific form of corruption when an individual grants themselves an undue benefit by exercising decision-making power for their own benefit(or that of a close individual).Common conf

268、licts of interest include hiring family members or favouring them as providers of goods or services.27Family tiesIn certain cases,a familial relationship with other employees,suppliers,distributors or third parties related to the company can potentially lead to a conflict of interest.Therefore,it is

269、 necessary to report such a relationship and analyse it in light of each specific case to take measures that prevent the conflict of interest from resulting in negative impacts on the company.A family relationship will be understood to include familial bonds up to the second degree of consanguinity

270、and second degree of affinity.The second degree of consanguinity includes grandparents,parents,children and grandchildren.The second degree of affinity includes in-laws,siblings-in-law,sons-in-law and daughters-in-law.Whenever a new candidate for a position is identified,the candidate must report th

271、e existence of a family member working for or providing services to the company.Similarly,any employee who has a family member joining the company as a supplier or distributor should report this for registration and analysis.Family members should not report to one another,either directly or indirect

272、ly,or be involved in the others employment-related decisions,such as hiring,performance reviews or recommendations for promotions.Examples of familial tie conflictsBOX 1A conflict arises when personal interest takes precedence over the companys interest.An example would be if a member of your compan

273、y had a cousin who ran a decoration company and could offer a good price for workin your office.In such a case,if personal interest is disclosed,the selection process is transparent,and the business side is handled by someone who is not a family member,no conflict arises.28Outside employmentA confli

274、ct of interest may arise if an employees outside employment negatively impacts their work at your company.Some activities should never be permitted,such as working for a competitor.Other activities,like outside opportunities with partners,suppliers or customers,may be permissible in some instances,b

275、ut only with proper approval.Outside employment means any position whether as an employee,consultant,contractor or owner in addition to your job at the company.Examples of outside employment conflictsBOX 2Examples would include a part-time job at a local coffee shop,service on the advisory board of

276、another company,consulting services provided to a friends business,and a conflict of interest that could also arise in the case of pro bono or volunteer activities.Financial interestA conflict of interest arises when an individual holds a personal or family financial interest in a customer,reseller,

277、supplier,partner or competitor if those interests would improperly influence their judgment and actions at the company.Financial interests include investment,ownership,creditor interests or any other financial arrangement that provides a share of profits or revenues.Business Integrity:A Toolkit for

278、Medium-Sized Enterprises32Conflicts of interest formName:Position:Department:ID number:Below,I present the conflict of interest situation in which I find myself(indicate one or more conflict of interest situations in which you or any of your family members or close friends are involved,such as relat

279、ionships with suppliers,customers,distributors,newly hired personnel,sale of services or products,etc.):_I declare that if there are any new situations of conflict of interest,I will report them through this form.Signature _Date _Manager declaration:I undertake to adhere to any conflict of interest

280、risk management plan and to monitor my employees adherence to the management plan,to ensure that the companys reputation and interest is adequately protected.Managers name _Managers signature _Business Integrity:A Toolkit for Medium-Sized Enterprises33Complaints frameworkTrust and satisfaction:A wel

281、l-defined complaints handling standards/policy ensures trust and satisfaction,legal compliance and enhances brand reputation.Accountability:When things go wrong,managing complaints properly is crucial.A complaints mechanism provides a structured avenue to voice concerns,ensuring transparency and the

282、 opportunity for remedial action within an organization.A structured complaints process is essential for safely reporting corruption-related risks.66.1 Benefits of a complaints frameworkA complaints handling framework establishes essential guidelines for addressing complaints,ensuring that employees

283、,suppliers and customers are well-informed of their rights and the procedures available to them in line with the companys anti-corruption policy and applicable laws.Employees and suppliers are at greater risk when reporting a complaint,and care should be taken to protect them.Setting up an effective

284、 complaint-handling system involves a step-by-step approach,and it is critical that you allocate the necessary time to ensure the quality and continuous improvement of the process.By implementing these practical examples,businesses can establish an effective anti-corruption complaint handling framew

285、ork that demonstrates their commitment to business integrity.It is a key element of a whistleblowing system to ensure there is no retaliation in practice for reporting potential wrongdoing.Clear and transparent:Ensure a clear and transparent framework,through a step-by-step approach and avoiding amb

286、iguity.The complaints handling standards/policy must be comprehensive and outline the businesss commitment to addressing and resolving complaints.Confidential:Maintain confidentiality to protect the privacy of the person raising an issue or filing a complaint.Offer anonymity to the personfiling the

287、complaint.Do not disclose details without the complainants explicit consent unless legally mandated.Accessibility:Prioritize accessibility by minimizing barriers for the complainant.Consider the needs of individuals in fear or those with special requirements.Quick response:Ensure a quick response on

288、ce a complaint has been received contributes to trustworthiness.6.2 Implementation tipsBusiness Integrity:A Toolkit for Medium-Sized Enterprises34Business Integrity:A Toolkit for Medium-Sized Enterprises346.3 Building a complaints frameworkChannel to report complaintsWhen designing complaints channe

289、ls it is important to define the options to report complaints,based on the resourcing that you can provide for this.Different users have varying preferences and limitations.Examples of channels that can be used include:Providing an email address allows customers to submit their complaints in writing

290、.Email is widely accepted and convenient for many users.Create a dedicated email address or online form on the website to submit complaints.Businesses should ideally offer both online and offline options.Online submission forms allow users to report complaints digitally and outside working hours,whi

291、le offline methods(such as paper forms)cater to those without internet access.Implement a suggestion box in a physical location where complaints can be filed.Sometimes,a face-to-face conversation is necessary.If possible,there should be designated personnel who can handle complaints in person,thereb

292、y adding a human element.SMS or other private messaging channels,such as WhatsApp,are a quick and efficient way for customers to report issues.Complaints channels should:Not incur any costs for users Offer a variety of contact methods tailored to the infrastructure available Be auditable and transpa

293、rentCommunicating complaints handling proceduresIt is essential to widely communicate the complaints handling procedure in accordance with the principles of transparency and accountability.What should be communicated?Clarify who is eligible to submit complaints (e.g.customers,employees,stakeholders)

294、.Explain where,how and when complaints can be submitted(e.g.online forms,email,in person).Define the scope of the process(what issues can be complained about)and any relevant limitations.Describe the potential outcomes from complaint handling(e.g.resolution,compensation).Specify the responsible depa

295、rtment and senior management function for handling complaints.Outline the process steps and expected timelines for complaint resolution.Guarantee confidentiality,anonymity and other rights for complainants.Explain how complainants can follow up(including appeal procedures).Detail how the business ha

296、ndles information disclosure and reporting on complaints.Mention any other relevant bodies(e.g.ombudsman)that can receive complaints.Examples of efficient practices that can be used:Clearly display information about the complaint mechanism on the company website,including who can submit a complaint,

297、how and where to submit a complaint,and contact details.Develop brochures or pamphlets that outline the complaint handling process and distribute them to customers at physical locations.Use social media and other communication channels to inform about the complaint mechanism and how to access it.Reg

298、ularly train and upskill employees and suppliers.Business Integrity:A Toolkit for Medium-Sized Enterprises35Effective management starts with the reception and documentation of complaints,ensuring they are addressed promptly and accurately.This is followed by a screening to determine the relevance of

299、 each complaint and the immediate resolution of those that fall outside the established scope.Complaints handling procedures should:Start by recording each complaint with a unique identifier and the date it was lodged.Promptly acknowledge receipt of the complaint and provide the complainant with an

300、overview of potential follow-up actions and expected timelines.Evaluate complaints against pre-defined criteria to determine if they fall within the mechanisms scope.Clearly communicate the reasons for the out-of-scope status to the complainant.Suggest alternative avenues for resolution.Examples of

301、efficient practices that can be used:Assign a designated staff member or team to receive and record complaints promptly.The staff member should be provided with sufficient independence to handle reports and be free from conflicts of interest.Develop a standardized template for acknowledging the rece

302、ipt of complaints and informing complainants about the next steps and expected timelines.Establish clear criteria for screening out-of-scope complaints and provide alternative channels or guidance for complainants in such cases.Ensure that staff members handling complaints are trained in maintaining

303、 confidentiality and protecting the privacy of complainants.Complaints handling principlesBusiness Integrity:A Toolkit for Medium-Sized Enterprises36To ensure a robust and fair resolution process,it is essential that all complaints falling within the scope of the complaints process undergo a thoroug

304、h overview.This entails a comprehensive analysis and fact-finding to establish a solid foundation for subsequent decisions.Such a reviewis conducted with the utmost independence,objectivity and impartiality to uphold the integrity of the process.Processing complaints should:Prioritize the accurate d

305、iscovery of facts.Ensure the preservation of evidence and minimize any potential influence on witnesses.Respect the rights and perspectives of the complainant throughout the investigation.Work in collaboration with law enforcement agencies and other relevant organizations as necessary.Maintain a det

306、ailed and chronological log of all activities and findings.Establish and uphold a clear chain of custody for evidence that may be used in future criminalproceedings.Examples of efficient practices that can be used:Conduct thorough investigations and fact-finding to gather relevant information and ev

307、idence.Collaborate with external experts or consultants,if necessary,to ensure an impartial and objective evaluation of complaints.Maintain a detailed log or case management system to track the progress of each complaint and document all actions taken.Regularly communicate with complainants,providin

308、g updates on the status of their complaints and any actions being taken.Processing complaintsOption 1:Complaints handled by the business itselfEffective complaint resolution is a dynamic process that should ideally be managed by the business receiving the complaint.This responsibility entails tailor

309、ing solutions to individual cases and acknowledging that a universal solution is not feasible.A thorough understanding of the legal context,as well as the social and economic landscape,is essential to address the nuances and ensure a fair outcome.Complaints handled by the business should:Assess the

310、complaints nature and the complainants concerns within the context of the social,political and economic environment.Ensure data protection and security measures are thoroughly considered.Engage with law enforcement agencies,competent institutions or other relevant parties when necessary.Implement ap

311、propriate corrective actions to resolve the complaint effectively.Maintain open communication with the complainant,providing updates on progress and information on potential corrective measures.Offer guidance on additional steps,including further actions,consultations,mediation and follow-up with pe

312、rtinent stakeholders.Examples of efficient practices that can be used:Tailor the resolution approach to the specific complaint and the needs of the complainant.Implement corrective actions to address the issues raised in the complaint and prevent similar incidents in the future.Seek feedback from co

313、mplainants on the effectiveness of the resolution and their satisfaction with the outcome.Continuously review and improve the complaint handling process based on lessons learned from resolved complaints.Option 2:Referral to a better-suited partyUpon completion of a thorough review and analysis,if it

314、 is determined that a complaint falls outside the scope of the framework or that it can be more effectively addressed by an alternative entity,it should direct the complaint to the appropriate party for resolution.This ensures that each complaint is managed in the most efficient and effective manner

315、 possible.Resolution of the complaint To ensure a robust and fair resolution process,it is essential that all complaints falling within the scope of the complaints process undergo a thorough overview.Business Integrity:A Toolkit for Medium-Sized Enterprises37Complaints referred to a better-suited pa

316、rty should:Initiate a discussion with the referral partner to determine their willingness and approach to address the complaint,ensuring adherence to principles of confidentiality and protection against retaliation.Obtain the complainants consent for the referral by informing them of the decision,ex

317、plaining the reasons and providing new contact details.Maintain regular follow-up with both the complainant and the referral partner to monitor the complaints progress.Offer assistance to the referral partner to navigate any challenges encountered during the complaint resolution process.Facilitate p

318、ositive relationships with relevant referral partners and,where feasible,establish a memorandum of understanding for handling future cases similarly.Engage in knowledge sharing with referral partners,offering advice and discussing best practices for implementing effective complaint mechanisms to add

319、ress corruption.Upon the satisfactory resolution of a complaint and the successful communication of corrective actions to the complainant,the case can be considered officially closed.This closure is not merely an administrative task and should be completed with the highest standards of service and p

320、rofessionalism.Closure of the complaint should:Inform complainants,where relevant,that their feedback has contributed to recognizing broader societal or developmental issues,leading to actionable measures for sustainable policy and practice improvements.Gather and secure proof of implemented correct

321、ive measures,such as photographic evidence,supporting documents,resolution records,agreements with the complainant or their written confirmation.Closure of the complaintAn appeal process should be established to ensure fairness and transparency.This process would involve an independent panel tasked

322、with reviewing the outcomes of complaints and decisions regarding complaints deemed outside the complaint mechanisms scope.Examples of efficient practices that can be used:Establish an independent review panel or designate another senior staff member not involved in the initial complaint handling pr

323、ocess to manage appeals.Clearly communicate the appeal process to complainants,including the necessary steps and timelines.Ensure that the appeal process is fair,objective and transparent,with decisions based on a thorough review of the complaint and any new evidence presented.Respect the outcome of

324、 the appeal and take appropriate action based on the decision.Appeal handlingBusiness Integrity:A Toolkit for Medium-Sized Enterprises38Business Integrity:A Toolkit for Medium-Sized Enterprises38Maintaining a comprehensive record of all complaints,follow-up measures and interactions with complainant

325、s are essential for promoting positive relationships and managing complaints effectively.The process for documenting complaints should:Establish a suitable documenting system,such as a complaints database,to manage and track issues effectively.Document all complaints,findings from investigations,sub

326、sequent actions,and interactions with complainants and partners in the database to maintain a comprehensive history.Implement a policy for anonymizing and archiving complaint records after a predefined duration post-resolution to protect privacy and manage data retention.An effective complaint mecha

327、nism is a vital component of a business,ensuring accountability and continuous improvement.For successful implementation,it is crucial to establish clear objectives,delineate responsibilities,allocate budget,set realistic timelines and provide consistent oversight.Regular monitoring and reporting ar

328、e also imperative to maintain the integrity of the process.Adequate staffing,precise role allocation,using suitable technologies and securing necessary funding are fundamental.Importantly,the resources allocated for the complaint mechanism must be safeguarded from influencing the resolution of compl

329、aints.Staffing and resource planning should:Establish distinct roles for strategic management of the mechanism,detailing the specific duties and authority of senior management.Set definitive deadlines for the receipt of complaints and the issuance of corresponding responses.Guarantee that the mechan

330、ism is sufficiently manned by personnel equipped with the necessary competencies to effectively handle complaints.Provide comprehensive training to staff on the proper treatment of complainants,ensuring impartiality,attentiveness to potential safety and security concerns,and prompt communication.Fun

331、ding:Securing adequate funding is essential for the establishment and ongoing development of an effective complaint framework.This financial support will not only assist in the initial planning and setup but will also ensure its maintenance and continuous improvement to meet evolving requirements.Su

332、ch a commitment to funding underlines the importance of a robust complaint mechanism in encouraging accountability and continuous enhancement of services.Resources and fundingDocumenting complaintsBusiness Integrity:A Toolkit for Medium-Sized Enterprises39ConclusionCorrupt practices pose substantial

333、 risks,undermining business health and acting as barriers to growth and investment.As the backbone of the global economy,SMEs have the potential to make a substantial impact in the fight against corruption.Business integrity is not just a moral imperative;for SMEs,it is a powerful driver of success,growth and resilience in todays complex global marketplace.Maintaining business integrity,however,re