Examples of good practice of preventing corruption
Companies can use the examples of good practices from this study to develop a plan for improvements in their ethics and anti-corruption systems.
A central purpose of this survey is to provide information that will enable all defence companies to improve their ethics and anti-corruption compliance systems. Some of that information comes from the overall Banding and the Banding in each of the five subject areas – allowing companies to see how they perform on an absolute basis and relative to the other defence companies. At a more technical level, information also comes from examining good practices that other companies have adopted: seeing whether they apply to your company, and tailoring them as necessary according to the circumstances. This study shows up many such good practices.
Most of them can be found on publicly available websites. Where the good practice is from non-published, internal company information, we have asked the company’s permission to reproduce extracts here. The examples are distinguished by being labelled either ‘Public’ or ‘Internal’. The internal examples are identified as part of our objective of informing all companies of examples of good practice so as to improve standards across the industry. Transparency International UK encourages companies to make all such examples public as part of their commitment to transparency.
In some cases, particularly among the personnel and helplines questions, a majority of companies had sufficient disclosure of good practice to warrant a ‘2’ score to those questions. As such, there are many possible examples of good practice, and we have chosen not to list these, on grounds of economy of effort and utility. In other cases there were very few good practice examples, most notably in response to the questions on leadership. We have accordingly have had a smaller selection to draw from to highlight the good examples in this subject area.
We have tried not to have ‘favourites’ among the good practice examples, but to seek out good practice from as wide a range of companies in different environments as possible. Nonetheless, those scoring in higher bands will also be the ones with the most good practice examples, so they will appear more often.
This process of collating the good practice examples is not yet complete, and we expect this part of the website to be additionally updated in the coming months.
To review examples of good practice by question, please download this PDF. Some questions have been grouped together because they share similar characteristics and are answered by similar sources. Further, since it is often worthwhile examining certain questions in the proper context in order to understand the full policies that companies adopt to safeguard specific corruption risks, the following questions have been grouped:
- Question A6: Appointment of a Board committee or individual Board member with overall corporate responsibility for its IBAC policy and programme
- Question A8: Appointment of a person at a senior level within the company to have responsibility for implementing the company’s IBAC programme, and who has a direct reporting line to the Board
- Question A11: Does the company have a formal anti-corruption risk assessment procedure for assessing business decisions, with clear requirements on the circumstances under which such a procedure should be applied?
- Question A12: Does the company have contractual arrangements and processes for the monitoring, control and audit of agents with respect to corruption?
- Question A13: Does the company make clear to contractors, sub-contractors and suppliers, through policy and contractual terms, its stance on bribery and corruption and the consequences of breaches to this stance?