2014-15 Canada-China Business Forum Magazine | Page 82
INTERNAL CORPORATE ENGAGEMENT
Engaging internal staff through CSR-related practices
and initiatives can boost morale and improve staff
retention. There is growing expectation that foreign
enterprises would support local charities and disaster
relief initiatives. However, internal CSR initiatives
need to be localized because ideas exported from
Canadian headquarters may be inappropriate. For
instance, some human resources managers may
view the introduction of flexible working schedules
as losing control over productivity. Certain teambuilding activities, such as pie-throwing contests may
cause managers to lose face in front of their teams.
•
Do you know what internal CSR
initiatives are expected of you?
•
What are the goals of internal CSR initiatives
and corporate engagement in China?
Retention of staff? Boosting morale? Boosting
productivity? Capacity building? Meeting
shareholder or stakeholder expectations?
Improving government relations?
•
How can you ensure buy-in, localization,
ownership and empowerment?
•
Are you communicating the objectives
of CSR initiatives clearly to your Chinabased managers and staff?
•
CORRUPTION & GIFT-GIVING
Tips:
Involve Stakeholders
Establish a local committee with key representatives
from the human resources department. Determine if it
is appropriate to allow other key staff to volunteer on
this committee. Explain clearly the goals of internal
CSR initiatives in Canada or elsewhere, and explain
how various initiatives in Canada have helped achieve
these goals. Determine with input from committee
members what the CSR goals are for China operations
and then determine which programs will meet
these goals. Establish a budget, assign roles and
responsibilities, and communicate progress to all staff.
Non-Governmental Organizations
If an initiative involves a local non-governmental
organization (NGO), be very careful that the Chinese
authorities properly sanction it. Also be careful that
it is not associated with a personal special interest
of an official, as this may be construed as bribery.
Preventing and detecting bribery
is increasingly important in
light of regulatory changes
over the past decade, which has
made corruption and bribery
of foreign government officials
a criminal offence in Canada
as well as in other jurisdictions
such as the U.S. and the U.K.
These countries are aggressively
asserting jurisdiction over the
foreign operations and business
practices of companies operating
in their respective jurisdictions.
Violation of anti-corruption laws
in Canada, U.S. and U.K. can
result in significant fines and
imprisonment for individuals
involved. In China, corruption
can carry the death penalty.
Education & Professional Development
Ideas to consider: recycling, carpooling, flextime,
volunteerism, community service, disaster
relief, education (including English lessons),
health and wellness, raising CSR awareness.
Educational opportunities for staff or
their families are highly valued.
Tips:
Develop an Anti-Bribery Compliance Program
A company should have an ethics policy, code of conduct or
specific anti-bribery policy that clearly spells out that both
giving and receiving bribes are illegal and forbidden. The
policy must spell out who is responsible and accountable for
the compliance systems and periodic review and updating of
the policy. The compliance program should include provisions
for staff training on the appointment of the company’s policy,
compliance with staff policies and periodic signing off on the
policy by all relevant staff. The policy should also address how
books and records are to be kept and what to do with regards to
reporting violations. As ethical breaches and corrupt activities
are, by their nature, very hard to detect, whistleblowing by
staff should be encouraged with a clear policy statement
that there will be no reprisals against whistleblowers.
Do Your Due Diligence
Any business partner or supplier who is less than transparent
with information will likely be deficient in other areas. Anticorruption due diligence should be conduc ted on all thirdparty business partners and suppliers that interact with
government officials or state-owned enterprises on your
company’s behalf. Due diligence is required to ensure such
parties are reputable and qualified to perform the services
they have been retained for and to detect historic or extant
corruption issues. Contracts with third-party business partners
or suppliers should also contain appropriate anti-corruption
representations and warranties. It should be noted that this is
very hard to do and specialized firms can be retained to help.
The CCBC and the Canadian embassy can provide guidance.
Know Your Supply Chain
Be suspicious of evasive, incomplete or dismissive answers
to questions about behaviour, corruption and bribery.
International legislation requires you to be aware of
all behaviour throughout your supply chain.
COMPLIANCE & LICENCES
Business licences in China can be very restrictive
and difficult to obtain. It is important to recognize
the limitations associated with the very large
Restricted Sectors and understand exactly what
business practices are allowed under each type
of business license you are applying for. Local
legal advice is essential during the licencing phase
of your business. It is also important to check
the licences of your partners and suppliers.
Do Your Homework
Tips:
Useful guidance can be had from Transparency International
Canada, their anti-corruption checklist and their workshops to
better understand anti-corruption legislation and what it means
for your business. Export Development Canada’s anti-corruption
quiz and its primers on the subject also provide useful guidance.
Conduct Audits Frequently
The ability to audit a contractor, supplier
or partner at any time is essential.
CANADA CHINA
FORUM
BUSINESS
2014-2015 ccbc.com
This informative guide was produced by the CCBC Corporate Social Responsibility
Committee. For more information or to learn more about the CCBC CSR Committee,
82
please contact Garrick Ngai, Director of Communications, at [email protected]