annahazar anti corruption

Anti-Corruption Views - ‘One size does not fit all’ in corporate anti-graft culture





A man walks over a colourful carpet at an exhibition stand at the Frankfurt book fair, October 16, 2009. REUTERS/Johannes Eisele.

If compliance with the U.S. Foreign Corrupt Practices Act and the UK Bribery Act is to become a reality it must become a daily part of the corporate culture, according to Mike Munro, vice president and chief compliance officer of Transocean, the world's largest offshore drilling company.

Speaking at the recent sixth FCPA and Anti-corruption Compliance conference near Washington, DC, Munro pointed out that every company is different and, when it comes to compliance, "one size does not fit all".

Specifically when it comes to multinationals, he said, it's important to remember that "we're not all Americans". In fact, some 70 percent of employees of multinationals are not Americans and training must be tailored to reflect that, he said.

At Transocean, he said, he worked to build a "brand" of compliance that came to be known within the company as LC&E, that is, Legal Compliance and Ethics. It took 2.5 years, but today every employee is aware of it, he said.

The motto of LC&E is "Everywhere...Every Day".
When it came to developing a compliance template, Munro said he stripped it of legal jargon and carefully put it in terms that could easily be understood by the engineers who make up the majority of Transocean's frontline personnel.
They are the people who would most closely encounter the risks of bribery in customs situations requiring expedition or oil rig crews requiring expedited work permits, for example.
As a result, he pushed the compliance message through the engineers themselves, not compliance officers and attorneys, he said.
Since companies deal with a number of foreign countries, Munro said he often sees the need to clarify the compliance message.
Specifically, he said, there are five areas where multinationals need to improve their compliance message:
1. All training material must be carefully translated into the local language.
2. All communications and policies have to be reduced to their simplest and clearest forms.
3. Trainers must be carefully chosen to mesh with the personalities, culture, age and rank of the personnel being trained.
4. Training materials must be tailored to local needs. Munro discovered that about 80 percent of training materials used U.S.-based names and situations. Using a guy called Mike as an example in a country where Mohammed might be a more common name is not useful. And it isn't helpful to include hypothetical situations more common to Manhattan than Mumbai, he said.
5. Make sure anonymous reporting of corruption works and is easy to do. Munro pointed out that a toll-free corporate helpline is no help at all in countries where you can't make a toll-free or collect call easily. He stressed that companies should make sure they procure access numbers for all of the countries in which they work.
"It's not easy and it's not cheap, but it's a good thing to do to have an effective programme and it's a good thing to do out of respect" to the local employees, he said.