Costs & Benefits of GE’s Anti-Corruption Program

Josie JardimGeneral Counsel Latin AmericaDiretora Jurídica para América LatinaGE

Latin America Conference on Corporate Responsibility for Promoting Integrity and Fighting Corruption

Agenda

Highlights of GE‘s Anti-Corruption Program

Costs

Benefits

The importance of the individual behavior

Additional Thoughts

3 /GE Executive Presentations /

May 2008

Highlights - GE’s anti-corruption program

Oldest remaining company in the Dow Jones….not because we are perfect, but because we’ve learned from our compliance history and mistakes and we’ve adapted.

Not just anti-corruption rhetoric

Not limited to FCPA compliance

4 /GE Executive Presentations /

May 2008

Costs – the obvious

$$$ & Time

Prevention: top compliance team, training, communication, policies & procedures, procedures,

controls

Detection: audits, ombuds program, surveys, metrics, Session D, early warning system

Response: investigations, discipline, process improvement

Leadership

Prev

ention

Detection

Response

If there isn’t a process that can be measured,

the compliance program does not exist

5 /GE Executive Presentations /

May 2008

Costs – The not so obvious

Unfair Competition

Though calls on GE Leaders who do not “get it”

Being so vocal about our anti-corruption program makes us sometimes “cutucar a onça com vara curta”

6 /GE Executive Presentations /

May 2008

Benefits – The obvious

Protects our Reputation

Avoidance of regulatory fines, penalties or lost licenses

The rules of the game are clear: do’s and don’ts …black and white---legal & ethical

Disciplined Processes

Early identification of issues

Reputation

2009 Hesburgh Award … exemplary ethical & governance practices

A World’s Most EthicalCompany … ’07 – ‘09

7 /GE Executive Presentations /

May 2008

Benefits – The not so obvious

Promotes Growth. It’s a competitive advantage w/ clients

Promotes the rule of law in the countries where we operate

It “raises the bar”

It provides a “safety net” for when formal controls are weak or absent

In the war for talent, it’s a retention tool

8 /GE Executive Presentations /

May 2008

Compliance depends on individual behavior…

9 /GE Executive Presentations /

May 2008

“Although some developed world corporations will affirmatively implement anti-corruption programs because of affirmative benefits inside the company, in the marketplace and in broader global society, many others will only do so if there is a real threat of negative impact--of national prosecutions causing catastrophic problems...”

Ben W. HeinemanThe Atlantic article - Transparency International USAFebruary 2010

The additional push…

QUESTIONS ?

Thank YouObrigadaGracias