Post on 23-Aug-2014
description
www.enrc.com Phone: +44 (0) 20 7389 1440
Communicating Corporate EthicsENRC Compliance
Michelle Witton – Compliance Lawyer
London, 11 June 2014
Reputation and Brand
Reputation and Brand
• New field / function – still very much evolving
• Behaviour (Win hearts & Minds) + Regulation
- Top down v bottom up approaches
• Internal messaging to build and sustain positive, compliant culture
• Real opportunities for creativity and working with Communications
to deliver impactful communications.
What is Compliance?
• Code of Business Conduct / Corporate ethics
• Anti-corruption (ABC) Policy + Gifts and Entertainment Policy
• Competition / Anti-trust Policy
• Ministerial Relations Policy
• Counterparty Due Diligence
• Trade sanctions
• Compliance Risk
• Compliance Training
• Monitoring + Auditing
Compliance - Areas
Bribery and corruption
TI Corruption Perceptions Index
UK
7.7
Trinidad & Tobago
3.6
Egypt
2.8
Indonesia
2.6
Libya
2.6
Angola
1.9
Azerbaijan
1.9
Iraq
1.312/06/2014 6
10 = Best possible Less than 5 = high risk
TI CPI 2013 – Least corrupt
UK
7.7
Trinidad & Tobago
3.6
Egypt
2.8
Indonesia
2.6
Libya
2.6
Angola
1.9
Azerbaijan
1.9
Iraq
1.37
10 = Best possible Less than 5 = High risk
Denmark 90Finland 90New Zealand 90
Sweden 88Singapore 86
TI CPI 2013 – Most corrupt
UK
7.7
Trinidad & Tobago
3.6
Egypt
2.8
Indonesia
2.6
Libya
2.6
Angola
1.9
Azerbaijan
1.9
Iraq
1.38
10 = Best possible Less than 5 = High risk
SOMALIA 8KOREA (North) 8AFGHANISTAN 8
SUDAN 13MYANMAR 15
IRAQ 18
FIFA – Doesn’t play fair….
FIFA Revised Code - My Game Is Fair Play
Siemens
Siemens – case findings
• $1.4bn total bribes paid
• 4,000+ improper payments
• Asia, Africa, Europe, Middle East,
Americas
• Usually paid by outside consultants hired
to help ‘win’ contracts
• Siemens paid fee to consultant, consultant
delivered cash to decision-maker(s)
• Dawn raids
• Simultaneous investigations across 20
countries
• 1,750 investigation interviews
• 500 employees disciplined
• From 5th to 50th preferred company ranking
• Loss of senior personnel
• Total penalty: $1.6b
• Additional costs: approx. $2b hidden costs
• Compliance monitor imposed for 4 years
Siemens – loss to business
Compliance and Communications –
Working together to achieve compliance
- Creating a strong brand for compliance
- Culturally relevant and resonant
- Enhance credibility
- Assisting employees to know
and apply the Code of Conduct
as the minimum standard
wherever we operate.
How are we achieving this?
• Clear visual identity for the Code &
Compliance.
• Easier to read, understand and recall.
• Communicate the Code to our people
in the most suitable way, depending
on location, role and position.
• Our people to tell the story of why it
matters.
Code of Conduct packs
• Code of Conduct packs produced in English,
Russian, Brasilian-Portuguese and French
• A language-specific DVD
• The ENRC Code of Conduct.
• Code “Z Card” with the key principles and contacts
for whistleblowing hotlines and helplines.
• Self-certification Certificate of compliance with the
Code, to sign and return to Compliance.
• Manual
• Website
• Intranet
• Chairmans office
Where can we find the
ENRC Code of Conduct?
Intranet
ENRC Global Whistleblowing Hotline NumbersEmployees who have any concerns or suspicions regarding a breach of the ENRC Code should raise these matters with their
line manager, local Human Resources contact, a higher level of management within their business unit or the General Counsel.
Whether it is bribery, corruption, discrimination, harassment, violence, legal, policy or regulatory violations, environmental issues
or any other matter, Employees should speak to someone about it.
If, for any reason, any Employee feels unable to talk to these people, they may bring their concerns to the attention of the ENRC
“Trust, but Verify!” external whistleblowing hotline. The whistleblowing hotline is a confidential, 24/7 service managed by an
independent company. It can be contacted by telephone or by email. The contact details are outlined below.
UK
Т: 0808 234 9574
Switzerland
Т: 0800 83 6056
South Africa
Т: 0800 891 2843
Mozambique
Т: 841199 (Vodacom)
DRC
Т: +243(0)82 302 7626
Brazil, Fale Conosco
T: 0800 891 2843
China
T: 10 800 110 1045
Dubai
T: 8000 021;
Code: 866 605 3095
Zambia
Т: 8000 021;
Code: 866 605 3095
Kazakhstan
Т: 8 – 800 121 4321
Pin: 866 605 3095
Russia
Т: 8 – 10 800 110 1011
Pin: 866 605 3095
W: http://hotline.enrc.com
E: compliance@enrc.com
ENRC does not tolerate any
harassment or victimisation
(including informal pressures or
any way of disadvantaging any
individual) and will take
appropriate action to protect
anyone who raises a concern in
good faith. If anyone tries to
discourage an individual from
coming forward to express a
concern, it will be treated as a
violation of the Code of Conduct
and of this policy, and as a
disciplinary offence.
Corporate Values Case Study - BP
Corporate Values – BP – Pre 2010
• Progressive
• Responsible
• Innovative
• Performance
Driven
Deep Water Horizon - 20th April, 2010
Corporate Values – BP – Revised 2012
“ We are BP ” – Safety
– Respect
– Excellence
– Courage
– One Team
Corporate Values – BP - 2012
One Team
• Whatever the strength of the
individual, we will accomplish
more together.
• We put the team ahead of our personal success and commit to building its capability.
• We trust each other to deliver on our respective obligations
Making values visual - Anglo American Guiding Values
Ethical decision-making
Ethical decision-making
Ethical decision-making
Ethical decision-making
Where do we work?
Where do we work?
Where do we work?
• Accessible, branded Code of Conduct
• Payslip reminders, Training Desk Certificates
• Intranet, internal publications
• Radio, Internal tv network stories, Promotional video
• Workshop and online training using scenarios
• Decision trees, Wallet cards
• Stickers, Mouse mats, Notepads
• Tablet app for Code of Conduct
• Annual Ethics award
Compliance and Communications – Project Ideas
33
Questions?