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Integrity Management
Ensuring Organizational
Compliance
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Health and Safety
Exits Facilities
First aid
Biological breaks
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Segment Outline
Objective:- Tools to support managementresponsibility for the behavior of others applicable
in private or public sectors
Evolution of the tools
References Key components
Development of the plan
What next?
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Modus Operandi
Maximizing your benefits Short presentation
Q&A period
Development of personal plan
Exercises Personal commitment
Discussion
Rules of Engagement
Respect Participation
The 1% probability
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Use of course materials
FIDIC grants to the attending participants the right ofpersonal use, or use for instructional purposes, of
any or all of the materials presented in this coursesubject to the requirement to identify FIDIC as thesource of the materials.
The materials may be reproduced without furtherlicense for the above purpose
Ownership of these materials is retained by FIDIC
Participants intending to use the materials for publictraining are encouraged to contact FIDIC to arrangefor updated materialswww.fidic.org
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A brief history.
FIDIC is 1990s focus on corruption
OECD work driven by 1st world agenda
1997 OECD Convention
FIDIC 1998 focus on integrity develop BIMS
Training guide in 2002
Model representatives agreement
GPIMS in draft 2008
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Currently.
MDB Activities Punishment vs. prevention
Cross debarring
Red flags development
Companies enrolled Trial of GPIMS
Users group
OECD submission
Companies selectively blackballing clients
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The three sides of corruption
The demand side The supply side
The condoning side
Real progress requires:-
Unanimity in the construction industry Integrity demands and behavior modification from clients
Financial acuity from the lender
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Scope of Integrity
Bribery payment made to unduly influence Extortion threats made to unduly influence
Fraud misrepresentation
Collusion cooperation amongst competitors to
unduly influence
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Key Principles
Integrity must be managed Leadership at the highest levels
Inclusion of all staff
Process systematic approach
Documentation continuous
Review and Improvement auditing, examinationand reporting of results, systems improvement
Relation to quality control procedures
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IM System Development
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Exercise One
Development of Code of Conduct
Integrity Defined
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Code of Conduct
In order for all members of an organization tounderstand the behavior that is expected of them,
and more importantly the limits of that behavior, acode of conduct must be established and agreed atthe highest level. This is the first step in developinga business integrity management system whetherfor a private or public organization. Typically, suchcodes are structured in terms of the stakeholders ofthe organization and reflect its values.
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Exercise
Use the following structure for a code of conduct tobe developed by each group
Social responsibility
Responsibility to the organization
Responsibility towards clients
Responsibility to staff
Responsibility to the industry
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Conflicts with legal dept
Tendency towards puffery in wording of codes ofconduct
Does code of conduct imply a higher standard ofpractice?
Statements in code of conduct need to be clear andunambiguous.
Codes of conduct will evolve over time iewhistleblower provisions
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IM System Development
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Appointment of leader/team
Direct report at highest level Can include outsiders
Influence required for success
Message of significance
Support for difficult decisions Ability to survive honesty
Initial focus on design
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Policy statement
The concept, approach and objectives of a firm withrespect to business integrity as formally defined and
expressed by management
Objectives
Approach Roles and responsibilities
Reviewing/Documentation
Reporting
Updating
Significance
Board level approval
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IM System Development
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IM System requirements
Influences on form of integrity system Geographic location (TI Corruption Index)
Structure
Geographic branch
Organizational functional departments
Scope of activities of organization
Legal and cultural environment
Alliances/relations to other entities
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Review of Current status of IM
Current practices Reputation of organization
Existing IM systems
Financial controls/audits
Potential to update Existence of QA system
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Communications Issues
Honesty Clarity
Issues
Guidance
Dialogue
Repetition
Consistency
Credibility
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IM System Development
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Detailed IM Policy Document
Fleshes out the policy document Translates behavior expectations into common
practice
Requires discussion/involvement of all staff first
steps in staff engagement Anchors the concept in the mind of every staff
member
Linkage with Core Values of Organization
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Detailed IM Policy contd
Individual behavior on discovering malfeasance Coverage of key subject areas:
- social responsibility
- compliance with laws
- impartiality
- confidential information
- conflict of interest
- misleading accounting practices
- giving/receiving gifts
- responsible use of property
- application to third parties
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IM System Development
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Components of an IM System Toolkit
Three kinds of system approaches Forensic auditing (catching after the event)
Red flags
Avoidance through organization (delegating responsibilityand authority pre-identification of the perpetrator)
Personal performance review component
Standardized procedures (prevention by system)
Integrity procedure audits
Integrity management practices should be described
for every key process in the organizations operation
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Systems review
Examine current practices of organization to identifyevery key process
For each process
Determine how the wrongdoing would show up in therecords of the organization
Identify additional records that could be used to make thewrongdoing more apparent
Identify steps to be taken in the auditing process to detectwrongdoing
Identifying persons responsible for integrity in operations Identify systematic actions to be taken to avoid wrongdoing
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IM Systmes Development
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Critical Projects vs All Projects
IM systems cost to implement Balance required
Selection of higher risk activities/projects
Routine random selection of others
Characteristics of a high risk project
Location
Size
Client characteristics other factors?
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Exercise Two
Conflict of Interest
Integrity by Avoidance
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Conflict of Interest
One of the most common dangers to integrity in theconstruction business is the existence of situations
which threaten the objective and unbiased behaviorof the parties towards one another and oftencompromise the confidentiality of information held
by one or more of the parties. In your groups list thetypes of conflict of interest that may be encounteredin your type of organization and devise methods tocounter such situations.
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Integrity control methods
Identified procedures to be followed to minimize riskof infractions paper trail
Typically identifies
Applicability and responsibility
Reference authority
Precursor activities
Actions to be taken
Monitoring
Documentation
Example Integrity Control Document
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Exercise Three
Prequalification
Integrity by Design
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Example - Prequalification
Circumstances of applicability Responsibility
Reference authority
Leading steps
Process description Documentation
Monitoring
Reporting
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IM Systems Development
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Implementation Tools
Code of Conduct Business Integrity Policy
Definition of roles responsibilities and authority (theteam)
Business integrity procedures for the mainprocesses
Accounting structure
Enforcement measures
Declaration in the annual report
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Training
The Board The IM team
Project managers
The staff
The auditors (internal) External auditors
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Review and revision
Senior review on a regular schedule Regular updating to accommodate changes in
organization
Updating from lessons learned
Careful version control so only current processesare used by organization staff
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The final word.
Straightforward approach incorporating Logic
Continuous improvement
Ethical considerations
Warning this may be revolutionary
Leads to questions of
Where we should be
Who we should deal with
What kind of work we should do
Also leads to A safer and better environment for everyone
Happier staff
A more sustainable organization
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