2. Increased transparency through corporate disclosure One of the topics addressed by new |
Disclosure of anti-corruption
efforts is not a new topic.
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ferences culture as one of the factors pertaining to a compliance programme working in practice. |
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regulations, such as the European Union
’ s Corporate Sustainability Reporting
Directive( CSRD), relates to disclosure
requirements. In the case of the
European Union ' s CSRD, the directive
will require companies to comply with
the European Sustainability Reporting
Standards, which includes corruption
and bribery under the governance pillar
.
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Increased transparency through
voluntary disclosure
can be useful to build trust
with external stakeholders,
mitigate reputational risk
and identify best practices.
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Active engagement in anti-corruption Collective Action can also be seen as a proxy for a strong commitment to integrity and continuous improvement relating to an ethical culture. While the concept of anti-corruption Collective Action emerged nearly two decades ago, the number of initiatives and diversity has gained significant momentum in recent years. At the end |
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Disclosure of anti-corruption efforts is |
of 2021, the Organisation for Econo- |
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not a new topic. Increased transparen- |
mic Co-Operation and Development |
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28 |
cy through voluntary disclosure can be
useful to build trust with external stakeholders
, mitigate reputational risk
and identify best practices. Companies
have long explored innovative internal
indicators to assess the effectiveness
of their efforts, which in turn informed
external disclosures. While no single
approach exists, several avenues are
worth considering.
In that regard, the Basel Institute has
facilitated the co-development of a
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UN Global Compact and the OECD Guidelines for Multinational Enterprises.
Five overarching themes have been identified based on their relevance to the prevention of corruption:
• Culture
• Risk management
• Third parties
• Compliance function
• Oversight
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( OECD) formally endorsed Collective Action to address corruption. This significant endorsement builds on increasing global attention to the need for multi-stakeholder collaboration to address complex global challenges and could also be one of the factors that prompted this recent uptake.
Measuring an organisation’ s corporate culture remains challenging, but the list of indicators developed by the Basel Institute can be used as a starting
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set of indicators that healthcare companies
may wish to consider when
reporting on the effectiveness of their
anti-corruption efforts to external
stakeholders. While these indicators
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The indicators are a combination of qualitative and quantitative metrics, some being goal-oriented, while others are binary( yes or no). |
point for companies looking to enhance external reporting on their anti-corruption programme.
Companies across nearly all industries
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were developed with healthcare companies
, they are not sector-specific and
could also be a useful approach for other
industries.
The indicators are included in a guidance
note which was developed with
Norges Bank Investment Management
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3. Measuring corporate culture The first theme of the Basel Institute / NBIM indicators focuses on culture. An organisation’ s culture impacts both behaviours and the effective implementation of anti-corruption programmes. |
will continue to face challenges when it comes to addressing the increasing jigsaw of varying international and national standards. Multistakeholder approaches, such as Collective Action, offer opportunities for companies to meet the expectations of stakeholders. |
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( NBIM). NBIM’ s publication of expectations
of companies on anti-corruption
refers to disclosure relating to the
measurement of the effectiveness of
anti-corruption programmes. These
expectations are based on internationally
recognised principles such as the
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The focus on disclosures relating to corporate culture has been gaining momentum in recent months. For instance, the U. S. Department of Justice latest guidance document, published in September 2024, on the Evaluation of Corporate Compliance Programs re- |
Collective Action can also help level the playing field with impactful strategies that will support transparency, ethical decision making and engaged leadership. A real commitment to sustainability requires a strong corporate culture focusing on integrity |