This page presents all relevant good practice case studies that showcase how business have addressed the Corruption dilemma. Case studies have been developed in close collaboration with a range of multi-national companies and relevant government, inter-governmental and civil society stakeholders. We also draw on public domain sources, including the UN Global Compact's own published Communications on Progress through which signatories are required to report on their performance against the Ten Principles.
The case studies explore the specific dilemmas and challenges faced by each organisation, good practice actions they have taken to resolve them and the results of such action. We reference challenges as well as achievements and invite you to submit commentary and suggestions through the Forum.
Alcatel-Lucent: Phasing out of third party agents and consultants – Global
In 2009, French-based technology company Alcatel-Lucent instituted a ‘zero tolerance’ policy to compliance issues, insisting upon “100 percent integrity in all business practices”. Under this policy, the company decided to phase out the use of external agents and consultants in order to reduce the risk of corruption. Instead, internal sales specialists were encouraged to develop new ways of engaging with markets. An added benefit of this approach has been to encourage closer client relationships by allowing for more direct contact between the company and its customers. The company takes a transparent approach to past allegations on corruption and other compliance issues. For example, it publishes what it terms ‘controversies’ on its website, including those relating to investigations launched in 2004 by the Costa Rican authorities into payments alleged to have been made by consultants for a subsidiary to public officials. Other ‘controversies’ include those relating to alleged bid-rigging and illicit payments by employees of a Taiwanese affiliate in relation to a Taiwan Railways contract, and concerns around alleged payments made to consultants in Kenya and Nigeria.
ABB: Business ethics standards based on the principle of ‘zero tolerance’ – Global
Swiss-based power and automation group ABB has published a set of business ethics standards based on the principles of ‘zero tolerance’, full and fair recording of transactions, continuous employee training and awareness-raising, and regular monitoring and reporting. Among other things, these standards cover conflicts of interest, bribery and corruption, agents and intermediaries, and political contributions. For example, employees should not seek or accept gifts with parties doing business with (or wanting to do business with) the company “which might reasonably be believed to influence business transactions”. Likewise, employees must not “offer undue monetary or other advantage to any person or persons, including public officials or customer employees, in violation of laws and the officials’ or employees’ legal duties, in order to obtain or retain business”. Similarly, commissions/fees paid to agents and consultants should be “reasonable in relation to the service provided”.
BASF: Network of 100 compliance officers headed by a Chief Compliance Officer – Global
German-based chemicals company BASF has an extensive compliance programme in place, which is aimed at preventing a wide range of legal violations, including incidents of corruption. In 2002, the company became the first in Germany to appoint a Chief Compliance Officer (CCO) – who is now supported by a network of 100 compliance officers worldwide. The CCO reports directly to the Board of Executive Directors on issues including the results of compliance audits and information gained from the company compliance hotline. All employees receive mandatory compliance training in the first year of their employment – supported by subsequent refresher courses (including interactive learning programmes). In 2009, more than 25,000 employees took part in compliance training. When selecting suppliers in non-OECD countries, the company uses a questionnaire to determine whether they have established a code of conduct and compliance guidelines. The BASF Corporate Audit department carries out audits of the Compliance Programme. In 2009, it performed 109 group-wide audits of the company’s dealings with business partners and government representatives.
BHP Billiton: Business Conduct Advisory Service – Global
BHP has established a global Business Conduct Advisory Service for employees, contractors and external parties to ask questions relating to business conduct or to raise a business conduct concern from any country in which the company has an operation or major office. The service is confidential, is available in a range of languages and can be accessed by a variety of means (including phone, Internet, fax or post). Although the company encourages business conduct issues to be raised and resolved locally, the service is provided in light of the need to provide a highly accessible service that allows issues to be raised outside normal management structures. The service is operated by EthicsPoint on a secure external server. BHP Billiton prohibits any form of punishment for raising or helping to address a genuine business conduct concern. The company notes that retaliation of this nature is grounds for discipline, including dismissal.
Fluor: Multilateral partnership via PACI and the American Society of Civil Engineers – Global/US
US-based engineering company Fluor is a founding member of the World Economic Forum’s Partnering against Corruption Initiative (PACI), which is led by the company’s Chairman and CEO Alan Boeckmann. The company’s approach is reflected in the company’s ‘zero tolerance’ approach to corruption – as well as its extensive ethics and compliance programme. In addition, Fluor works with the American Society of Civil Engineers on anti-corruption and Boeckmann is honorary chair of the group’s Anti-Corruption Education and Training Project (ACET). The centrepiece of ACET is the ‘Ethicana’ movie, which examines corruption in the global construction industry – and what can be done about it. The movie – which Fluor contributedUS$100,000 towards– includes dramatised bribery situations, as well as discussion topics, train-the-trainer instructions and takeaway materials. The video is being provided free of charge to companies, government agencies and universities around the world. Fluor also maintains strong relations with Transparency International, which it provides with financial support.
Merck: Full transparency around grants to medical, scientific and patient organisations – US
Pharmaceutical company Merck takes a particularly transparent approach in disclosing grants to medical, scientific and patient organisations (both inside and outside the US), payments to US-based healthcare professionals, philanthropic grants, political contributions and clinical trial disclosures. In doing so, the company offers a particularly high level of detail in its disclosures. For example, grants to medical, scientific and patient organisations in the US are broken down into quarterly spreadsheets detailing payments of hundreds of dollars to hundreds of thousands of dollars. Likewise, non-US grants (to countries ranging from Algeria to the UK) are broken down by country on an annual basis.
Norsk Hydro: Navigating the ‘grey areas’ through the assessment of corruption risks – Global
Norwegian aluminium and energy company Norsk Hydro acknowledges that when working in developing countries, there can be ‘grey areas’ that can be difficult to navigate. The company provides a case study outlining its approach to entering into new activities or relationships. This includes a risk assessment of the country the company will operate in. The company also reviews prevailing socio-economic conditions – and a range of other issues, including review of Transparency International’s Corruption Perceptions Index. In addition Norsk Hydro carries out ‘integrity due diligence’ of potential partners and consultants. This includes backgrounds checks, media reviews and identification of previous legal incidents. When working together with third-parties, project managers and line management undertake continual assessment – as well as a review of status at project milestone stages. Nonetheless, the company acknowledges that it is sometimes necessary to be sensitive to the fact that other cultures sometimes have a different approach to some of these issues – whilst at the same time sticking to the company’s guidelines.
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