RAISING THE BAR THROUGH COLLECTIVE ACTION Anti-Corruption Efforts in Action in India
RAISING THE BAR THROUGH
Anti-Corruption Eﬀorts in Action in India
Shabnam Siddiqui & Yamini Suvarna
A Collective Action Project Publication
GLOBAL COMPACT NETWORK, INDIA
We would like to express our sincere appreciation to all the authors
who have contributed valuable insights and inputs for this guide, and
responded to multiple queries with enthusiasm. A special thank you to
Ms. Chetna Kaji for being on hand for language correction throughout the
process of publication.
This publication was edited by Shabnam Siddiqui and Yamini Suvarna.
The views expressed in this publication are the authors’ own and do not
necessarily represent the views of the Global Compact Network, India.
The Global Compact Network, India makes no representation concerning,
and does not guarantee, the source, originality, accuracy, completeness
or reliability of any statement, information, data, �nding, interpretation,
advice or opinion contained within the publication. This publication is
intended strictly as a learning document. The inclusion of case stories
and examples of company experience sdoes not in any way constitute
an endorsement of the individual companies nor their anti-corruption
policies by the United Nations Global Compact Oﬃce and/or Global
Compact Network, India.
The material in this publication may be quoted and used provided there
is proper attribution.
This publication is brought out through the generous contribution of the
Siemens Integrity Initiative Fund.
Developing an Anti-Corruption Policy: Paharpur Business Centre 3
E-Procurement at Neyveli Lignite Corporation 17
Governance and Culture at Tata Chemicals Limited 29
Ethics and Compliance for Pro�table Businesses:
The Siemens Experience 39
Anti-Corruption and Anti-Bribery Program:
Enlightening Practices in Tata Steel 51
Anti Corruption Practices at Infosys Ltd 59
Bill Watch System: A Case Study of Gail 71
Vigilance and Transparency: Issues and Challenges 81
Collective Action Across Private and Public Enterprises:
Mjunction’s Movement for Eﬃciency and Transparency (MET) 91
Looking Ahead 101
About Collective Action Project in India 104
The United Nations Global Compact (UNGC) recognizes corruption to
be one of the greatest challenges and a major hindrance to sustainable
development, with a disproportionate impact on poor communities and
is corrosive on the very fabric of society. In rapidly evolving markets, like
India, corruption is a bottom-line business issue that directly aﬀects the
Financial Integrity report, India lost a total of $462bn in illegal capital
�ows between 1948 -2008. The same report further states that the illegal
�ight of capital through tax evasion, crime and corruption has widened
inequality in India. Citizens lose faith in their government in societies
where bribery persists and corrupt oﬃcials are not held accountable. A
survey conducted by The Times of India published in Feb 2011 reinforces
this; over four-�fths of the respondents opined that corruption was at an
all-time high, two-thirds maintained that the government was not serious
about tackling it, while over ninety percent stated that corruption had
tainted the government’s image.
The United Nations Convention Against Corruption (UNCAC) was rati�ed
by India on May 1, 2011. The 10th UNGC principle states that “Businesses
In pursuance of this principle, in December 2010, United Nations Global
Compact (UNGC) launched the Anti-Corruption Collective Action Project
(CAP) in �ve countries – Brazil, Egypt, India, Nigeria and South Africa – with
support from Siemens Integrity Initiative Fund. The aim of the project is
to foster a high-impact collective action platform on anti-corruption by
facilitating on-going dialogue between private and public sectors and
devising business integrity measures, on the basis of the 10th UNGC
principle, to facilitate companies to operate with UNCAC recommended
standards. Additionally, it attempts to provide an enabling platform at the
country level where multiple stakeholders can address issues related to
corruption. CAP is a forum to share information and experiences and �nd
ways and means to collectively �ght against corruption.
This publication is an eﬀort by CAP to bring to the fore, the work done by
public and private enterprises in India to combat corruption and enhance
compliance. It showcases how companies from both private and public
sectors contribute to advancing the anti-corruption agenda through
speci�c actions beyond the introduction of policies. It includes nine case
studies (3 public and 6 private) that focus on diﬀerent aspects such as the
aspects of such policies, challenges faced when implementing the policies
and eﬀorts towards collective action.
I would like to acknowledge and appreciate the support of the senior
management of the participating companies for their contributions to
this study. It is my sincere hope that this book will prove to be a guide and
an inspiration to all those seeking to overcome corruption dilemmas in
Global Compact Network, India
“Hard but necessary choices lie ahead. We need an outcome
that is simultaneously practical and transformational. We
must use Rio+20 to promote better respect for nature and to
cultivate an environment – natural and social – in which all
children feel safe and all people can prosper. Mother Earth
that all of us must seize.”
— UN Secretary-General, Ban Ki-Moon
Transforming the business climate in India from one where corruption is
not only tolerated but sometimes even encouraged, into a zone of zero-
tolerance for corruption where compliance and governance is a norm,
is a daunting task and requires eﬀort at multiple levels. The three levels
to �ght corruption identi�ed by stakeholders of United Nations Global
i. Internal – where a company assesses risks, implements anti-
corruption policies and compliance programs and provides
guidance to managers.
ii. External – shares internal policies, experiences, good practices
and success stories with external stakeholders.
iii. Collective – reaches out to industry peers, suppliers and other
stakeholders and initiates joint activities to �ght corruption.
Pettigrew and Whipp (1991)1
further identi�ed three dimensions of
strategic change. They maintain that there is continuous interplay
between these change dimensions and that successful change is a result
of the interaction between the content (objectives, purpose and goals);
the process (implementation) and the organizational context (the
internal and external environment). Please see Figure 1 for a diagrammatic
representation of these dimensions with reference to the creation of an
anti-corruption business culture.
Content centres on the objectives, purposes and goals of the change
Figure 1: Three Dimensions of Strategic Change
In the context of the Collective Action Project, the focus is on changing or
transforming the business culture to one that is more transparent.
The process implies implementation and the focus is on developing
strategies to bring about the change. The development of anti-corruption
practices by companies in both the public and private sectors can be
viewed as the �rst stage in the process of strategic change. As a part of the
second stage, companies would be required to take the necessary steps to
ensure the actual implementation of these policies.
Context refers to the environment where the change is taking place and
comprises both the internal and external environment. The development
and implementation of anti-corruption policies within companies
are indicators of change in the internal environment while meetings,
consultations, seminars and training programs organized by the Collective
Action Project are changes that take place in the external environment.
Steps are taken by companies to ensure that all business practices
conducted with their suppliers/vendors/customers also fall within the
ambit of the external environment.
An Overview of this Book
The nine cases presented in this publication are drawn from both public
aspect of policy or practice that a particular business has implemented, or
is in the process of implementing, and one case details implementation
challenges encountered and the eventual impact. The publication is
divided in three sections: the �rst section outlines case studies that have
focused on process development; second section mentions a case that is a
bridge between process and implementation; and the third section details
cases of implementation and operation.
The �rst three case studies (in the �rst section) focus on the anti-corruption
policies developed by the companies and detail the processes involved in
the creation and implementation of these policies. The �rst of these cases
presents the rationale and the processes followed for the development
of the Anti-Corruption and Ethical Policy information by the Paharpur
Business Centre & SoftwareTechnology Incubator Park whilst emphasizing
the company’s commitment to safeguarding the environment. The
second case, taken from the public sector, focuses upon the eﬀorts made
by Neyveli Lignite Corporation to implement the Integrity Pact and
describes the E-Procurement system and the Online Integrated Material
Management System set up as part of the company’s eﬀorts to prevent
corruption and encourage transparency in their business dealings. The
third case outlines the Governance Policies at Tata Chemicals Limited, and
discusses the formal as well as informal systems and practices that have
been put in place to ensure ethical compliance.
The fourth case draws on the Siemens experience and details the Siemens
Compliance Guide for Anti-Corruption. This case highlights the fact that
businesses can be both, ethical and successful.
on the implementation of the policies in the concerned companies. The
�rst of these comes from theTata Group and details the diﬀerent policies in
place at Tata Steel and the steps taken to implement these so as to curtail
corruption and create an appropriate anti-corruption and anti-bribery
environment across Tata Steel. The second case of this section provides
information on the Value Program implemented by Infosys to ensure that
all employees assimilate the Infosys corporate and business values and
practice it in their daily work-life. The seventh case study, also the last one
in this section details the eﬀorts of Gas Authority India Limited, a public
enterprise, to make the entire billing process more transparent and user
The penultimate case study is unique in that it presents a case of
irregularities in maintenance work done and related corrupt practices in
a premier public management institute which resulted in a formal fact
�nding enquiry. [The name of the company, and people involved have
been changed for purposes of con�dentiality].The �ndings of this enquiry
and resulting disciplinary action is mentioned.
And the last case study is an example of collective action in practice, in
the steel industry. It details the formation of mjunction Services Limited, a
public-private joint venture which combines technology and the Internet
to reach out to a large customer base and ease the process of sales for
The last case study also showcases the Movement for Eﬃciency and
Transparency (MET) initiative that aims to recognise, appreciate and
and opaqueness, where they can share their success stories and ideas for
The publication ends with a special chapter titled ‘Looking Ahead’
contributed by Dr. A.K. Balyan, Governing Council member of Global
Compact Network, India wherein he outlines the strategies of Collective
Action that need to be taken in the times to come.
Dynamics of Change
The above mentioned case studies respond to four aspects of change as
enumerated in Figure 2.
• Personal – This centers on the anti-corruption policies in place in
the company and are applicable to all the personnel across the
company and its subsidiaries. The Anti-Corruption and Ethical Policy
at Paharpur Business Centre & Software Technology Incubator Park
(Case 1), Tata Code of Conduct (mentioned in Cases 3 and 5), the
Siemens Compliance Guide for Anti-Corruption (Case 4) and the Code
of Conduct at Infosys (Case 6) are a few examples of such policies
mentioned in this publication.
policies as well as the interactions and linkages between the diﬀerent
subsidiaries/departments of the parent company. This could take the
form of speci�c policies created for diﬀerent areas or departments or
functions as in the case of the Code of Ethics for Principal Executives
and Senior Finance Oﬃcials in place in Infosys (Case 6), Gift and
Hospitality policy at Paharpur Business Centre & Software Technology
Incubator Park (Case 1) or the whistle blower policies in place in
many of the participating companies (Case 4 and Case 6 contain two
examples of such policies). Case 8 in this publication highlights the
pitfalls of not having independent departments and shows how the
absence of these can enhance a company’s vulnerability to corrupt
• Structural – Bringing about change at the structural level
requires companies to examine how their anti-corruption laws
have been structured and monitor the systems in place to ensure
their implementation. The E-procurement system and the Online
Integrated Material Management System (OLIMMS) set up by Neyveli
Lignite Corporation (Case 2) and the Bill Watch System in place in
Gas Authority India Limited (Case 7) depict policies that have led to
Figure 2: Four Aspects of Change
• Cultural – The focus at this level is on determining how companies
can go beyond their own employees to take anti-corruption policies
to others thereby creating a business climate that displays zero-
tolerance towards corruption. Many of the companies featured in this
book have policies in place to ensure that their customers/vendors/
clientele also conduct business in an ethical manner eschewing
corrupt practices. However, the MET initiative mjunction (Case 9)
is a �ne illustration of how collective action as well as recognizing,
appreciating and felicitating people who have transcended barriers
of bureaucracy, ineﬃciency and opaqueness can contribute to the
creation of a business climate conducive to compliance.
The editors hope that this book would inspire other Indian enterprises
to share and contribute their own insight and experiences on tackling
corruption in an eﬀective manner.
Developing an Anti-Corruption
Policy: Paharpur Business Centre
DEVELOPING AN ANTI-CORRUPTION POLICY: PAHARPUR BUSINESS CENTRE 3
This article provides information on the
Paharpur Business Centre & Software Technology
Incubator Park (PBC™- STIP). The rationale and
the processes followed for the development of
the Anti-Corruption and Ethical Policy in keeping
with the principles of the UN Global Compact
are detailed in this article. The author also draws
attention to PBC’s commitment to safeguarding
Developing an Anti-Corruption Policy: Paharpur
– STIP is a Micro Small and Medium Enterprise (MSME) in the service
sector, housed in an independent six-storied building with an area of
50,000 sq. ft. It is a 25-year-old building located within Nehru Place Greens
and built to Government speci�cations. It is the �rst oﬃce building in India
to be USGBC LEED1
Platinum certi�ed under Existing Buildings (Operations
& Maintenance) category – sustainable building. It also has a Bureau of
Energy Eﬃciency (BEE) with a �ve star rating, with a certi�ed annual energy
consumption of 28Wh/hr/m2. It is an ISO (International Organisation of
Standardisation) 9001, 14001, 22000, OSHAS (Occupational Health and
Safety Advisory Services) 18001 and SA (Social Accountability) 8000
certi�ed company. Paharpur Business Centre (PBC) has been recognized
for its transparent business practices and was presented an‘Ethics is Good
Business’award, in December 2005 by Dr. A. P. J. Abdul Kalam, the President
of India at that time.
PBC began its operations in the 1990s with an equity capital of less than
US $ 15,000. Today the current net worth is US $ 13.94 million.
PBC is a ‘partner of choice’ oﬀering a suite of 28 support services in Delhi
and NCR. It has been a leading provider of oﬃce facilities and services
to corporates as well as fortune 500 companies planning forays into the
Indian marketplace, for nearly two decades now. One of PBC’s USP is the
promotion of the concept of entrepreneurship where each HOD (Head
U. S. Green Building Council – Leadership in Energy and Environmental Design
4 DEVELOPING AN ANTI-CORRUPTION POLICY: PAHARPUR BUSINESS CENTRE
Figure 1: Organogram
Paharpur Business Centre & Software Technology Incubator Park
DEVELOPING AN ANTI-CORRUPTION POLICY: PAHARPUR BUSINESS CENTRE 5
of Department) is given the opportunity and independence to run the
department as they would run their own business.
Please see Figure 1 for the organogram.
The client list of PBC includes several Fortune 500 companies - Microsoft,
Hewlett Packard, Mobil, Motorola, British Telecom, SAP, Singapore
Telecom, Comverse Network, GEC Alsthom, Intel, Matsushita Electric, Sun
Microsystems, Alta Vista, Hitachi, Daiken, Associated Press and Symantec.
Apart from providing serviced and furnished oﬃces on a ‘plug and play’
basis, the services oﬀered by PBC are as under:
1. Clean AirTM
- Maintaining indoor air quality as per speci�ed by
the ASHRAE (American Society of Heating, Refrigerating and Air-
Conditioning Engineers) standards. This service focuses on providing
indoor consulting services to corporate and Business houses.
2. Spring CleanTM
– Housekeeping and maintenance services. Mechanized
cleaning and maintenance solutions for buildings, oﬃces and homes
are oﬀered as part of this service.
3. Happy GreensTM
– Horticulture services.“Say it with �owers”is the motto
maintenance of plants, garden maintenance and landscaping.
4. Be AssuredTM
– Security services. The security services team provides
consultancy, private investigation, as well as guarding and canine
5. My ConferenceTM
– Conference facilities. This is ideal for corporate
seminars, board meetings and private client meetings. It is equipped
6 DEVELOPING AN ANTI-CORRUPTION POLICY: PAHARPUR BUSINESS CENTRE
with state-of-the-art facilities like VOIP, WiFi, LAN and audio/video
– Engineering and safety services. On oﬀer is a highly
quali�ed and professional team that provides engineering, safety and
audit services for oﬃce and building equipment.
7. Indian SpiderTM
– The Internet Service Provider. It provides broad
bandwidth and VOIP along with other modern technology to
complement business needs in Delhi.
8. Oﬃce SupplyTM
– Oﬃce Supplies. Oﬃce stationery and computer
related supplies at the doorstep at economical prices.
9. Cuisine ArtTM
– an ISO 22000 certi�ed provider of food and beverage
services. CuisineArt is an exclusive preserve providing gourmet cuisine
backed by a team of professionals. It is a favorite with Corporates
and Embassies and known for its high quality of food and courteous
service with a smile.
10. Café EinsteinTM
– A gourmet-eating experience at the Centre with
organic options. The restaurant specializes in power buﬀet lunches,
corporate get-togethers and dinner parties.
11. Fin TaxTM
– Financial and Legal services. This takes care of tasks like
processing of payroll, tax advice, insurance and bookkeeping and
ful�lling government regulations.
12. Micro ManageTM
– A Green Integrated Facility Management service
provider. This unit provides both soft and hard services, which include
turnkey facilities and management solutions customized to the needs
of the clients.
– Corporate Valet Service.This service is a facilitative one, which
puts clients in touch with leading professionals providing a variety
of services related to law, accounting, auditing, market research,
recruitment and taxation.
DEVELOPING AN ANTI-CORRUPTION POLICY: PAHARPUR BUSINESS CENTRE 7
14. Travel SpiderTM
– Travel management services. An IATA & ASTA
approved travel agency with a corporate focus, it is a preferred travel
agent for corporates operating in India.
15. ReLo cateTM
– Realty services. This team provides assistance for short
and long-term real estate needs, both commercial and residential.
16. Business PointTM
– Virtual Oﬃce facilities. Resident secretaries for
traveling executives, mail and message forwarding, appointments, fax
and secretarial assistance are all provided through this service.
17. PBC Art Gallery – A free art platform to encourage the emergence of
new artists, in line with the organization philosophy - Art for a Cause.
18. Green GrocerTM
– Farm fresh fruits and vegetables, organic vegetables
and grocery services.
19. Out ReachTM
– Training and HR consulting services.
20. Quality LifeTM
– Quality management services.
21. Clear VoiceTM
– High quality VOIP service.
22. PBCPR – Corporate Communications division that functions as an image
consultant enabling one to present one’s best fact to the world.
23. My OﬃceTM
– Fully equipped oﬃces and workstations designed for an
24. My TrainingTM
– Training facilities
25. My InterviewTM
– Interview rooms
26. Legal SpiderTM
– For independent research on Indian and UK laws.
27. Deutsches Haus – This unit provides German language support,
translation and interpretation services to MNCs.
PBC is deeply committed to maintaining excellent employment standards.
While attracting and retaining great talent is a given objective at PBC, it
8 DEVELOPING AN ANTI-CORRUPTION POLICY: PAHARPUR BUSINESS CENTRE
also works consistently to hone skills of existing employees to reduce the
business model for all.
A positive/enabling work environment is essential to allow employees
to achieve their potential. It also helps attract new employees to PBC
and motivates them to stay on. Components of the enabling work
environment include numerous opportunities for employee development
and professional growth, competitive compensation and bene�ts, focus
on health and safety, and approach to diversity and inclusion.
Table 1: Employee Information
Employee Details 2010 – 2011
Number of employees: Permanent 210
Number of management (or executive/oﬃcer) 31
grade employees (Nos.)
Ratio of non-management cadre to management 14.76%
Segmentation of employees by gender
Male (Nos.) 174
Female (Nos.) 36
Segmentation of top management by gender
Male (Nos.) 17
Female (Nos.) 14
Commitment to Principles of UN Global Compact
PBC is strongly committed to the ten principles of UN Global Compact. It
conducts itself in a responsible and ethical manner, ensuring transparency
in all its dealings, especially in its supply chain management to assure all
stakeholders of its accountability and responsibility. Strict adherence to
DEVELOPING AN ANTI-CORRUPTION POLICY: PAHARPUR BUSINESS CENTRE 9
the laws of the land; both statutory and regulatory compliances, are an
essential aspect of all PBC business operations.
Regular internal audits are carried out by their Quality Assurance (QA),
Finance, Human Resources (HR) and Legal Departments to ensure
standards, codes and other statutory and regulatory requirements are
regularly updated whilst also controlling and monitoring all operations.
Third party audits of the various management systems provide an
unbiased audit of the systems concerned. The SOPs and standards of PBC
take care of all legal requirements, which are an inherent/intrinsic part of
In case any business unit/department is found to be non-compliant
during the audit process, immediate corrective action is taken in terms of
re-de�ning of SOPs (Standards of Operation), getting the same in place
and reviewing it for further compliance and adequacy.
– STIP, policies are developed in a transparent manner to prevent
corruption. Eﬀective controls that check unethical behavior whilst
ensuring that PBC’s core values and ethics are clearly understood by all
the important stakeholders are embedded in all its operations.
The company manual‘Management Standing Instructions’(MSI) lists down
all the policies as well as the ‘Dos’ and ‘Don’ts’, which is an integral aspect
of the formal induction process that every new employee undergoes. In
addition, regular training programs and workshops conducted by the HR
department ensure that the team members are aware of the core value
system of the organisation.
At PBC, personal integrity and integrity in business are regarded as
important prerequisites for recruiting/employing talent, signing business
10 DEVELOPING AN ANTI-CORRUPTION POLICY: PAHARPUR BUSINESS CENTRE
MOUs, �nalizing vendors/sub-contractors or forging new partnerships.
Each department identi�es its speci�c legal requirements and receives
assistance from the commercial and legal department to put these in
The company does not condone any violation of the law, unethical
fraud and theft. Any employee violating the company’s code of conduct
and/or exhibiting unethical behavior is subject to an investigation and
appropriate action is taken against the violator in an impartial/unbiased
In keeping with PBC’s Gift and Hospitality policy, no PBC employee or any
member of his/her immediate family is allowed to accept any form of gifts
or favors from contractors, suppliers, clients/customers, or any other party
having business dealings with the company. However, in such circumstances
where it is customary to do so, employees are permitted to accept such gifts
of nominal value or favors provided that such gifts or favors are not extended
and/or accepted for the purpose or with intention of:
• In�uencing any present or future act decision by that employee.
• Inducing such employee to perform or omit any act in violation of his
proper duties and responsibilities.
• Inducing such employee to use or direct any other person to use his
in�uence with a government, or any of its representatives, divisions
or agencies to aﬀect or in�uence any act or decision of any such
government, representative, division or agency and in any or all of the
above cases, for the purposes of expediting, bene�ting, prejudicing
or aﬀecting in any way whatsoever whether directly or indirectly the
business dealings or relationship of the gift giver with the company.
DEVELOPING AN ANTI-CORRUPTION POLICY: PAHARPUR BUSINESS CENTRE 11
• For the purpose of this section, “Nominal Value’ of a gift is de�ned as
the sum of the gift(s) having the aggregate monetary value of not
more than Rupees Three Hundred only (Rs. 300/-). Employees are
required to report to their respective Head of Department on all gifts
or favors received which exceed the above nominal value.
• Any employees in doubt as to the nature or purpose of the gift or favor
must consult the HR Manager who will decide, either in consultation
with or through his/her own accord, the course of action in respect of
such gift or favor.
• Gifts that exceed the nominal value stated above, cannot be accepted
by PBC employees and will be returned to the donor; or if such return
is not possible, the company will retain the same for distribution to
recognized charitable organizations.
PBC’s determination to go beyond compliance is evidenced from the fact
that it is a signatory to policies and frameworks developed by international
bodies like UNGC and GRI – OS. The company strongly believes that
voluntary compliance to international standards and benchmarks is the
PBC’s Anti-Corruption and Ethical Policy
– STIP has a stated anti-corruption and ethical policy monitored
by Human Resource Department and all the HODs in their respective
business area. PBC provides the wherewithal to all the departments to
ensure the success and pro�tability of their business ventures without
compromising on the core values of conducting business such as
responsibility, transparency and sensitivity towards the environment. This
makes it necessary to have clear cut policies and guidelines that constantly
guide business heads.
12 DEVELOPING AN ANTI-CORRUPTION POLICY: PAHARPUR BUSINESS CENTRE
The anti-corruption policy was initiated on April 28, 2011 by Quality
Assurance (QA)/Sustainability Department. It was then discussed with the
CEO who was dedicated to the formation of a proper system to address
corruption and ethical dilemmas faced by the employees.
The framework of the policy was created by the Heads of the various
departments, the General Managers and the CEO, with inputs from
speci�c departments like HR, Finance and QA. The process involved
two or three brainstorming sessions where practices adopted by other
organizations were discussed. The nature of business conducted at PBC
and the interaction of the various HODs with various stakeholders of PBC
were kept in mind to arrive at a policy that addressed the speci�c needs
and concerns of the PBC family.
The �rst step in the development of the policy focused on the Heads of the
departments.The involvement of the HODs ensured that they understood
the signi�cance of the development of this policy and its impact on
the business practices of the company. It also provided the HODs an
opportunity to present their views and provide inputs on the components
of the policy.
Drawing from the inputs from the business heads, a team comprising
key players from the QA and HR department and the GM’s Committee
developed a policy framework. This was discussed with the CEO for inputs
which were included in the preparation of a policy document. This was
presented to the board by the CEO for the �nal approval which was given
on May 26, 2011 indicating that the entire process took less than one
This policy (detailed in Box 1) was then circulated to all the employees of
PBC who are required to ensure strict adherence to the policy and behave
BOX 1: Anti-corruption & Ethical Policy at
As employees in PBC, we:
• Will ensure to behave in an honest and ethical
• Will set a good example by being trustworthy.
• We will make sure that our behavior
complies with the policies and rules of the
• We will use the resources of our company
in the best interest of the company, and not
for personal and gainful reasons. We will not
misuse these resources.
• We will not pay or accept bribes/anything
of value/cash/gift/gratuities, oﬀer of
employment etc, for the purpose of
in�uencing placement of contracts, obtaining
a business advantage or any other reason.
• We will make a clear distinction between the
interests of our company and our personal
interests, and avoid possible con�icts of
interest; we do not accept gifts, invitations or
other advantages, which could contradict this
principle or in�uence our business decisions
that are against the norms of our company.
• Ensure that we comply with law of the land,
including National legislations and statutory
• All commissions and fee contracts shall have
prior approval of our CEO.
• Report incidents, risks and issues which
deviate from our policy, to your immediate
reporting authority, or Head-HRD or CEO.
DEVELOPING AN ANTI-CORRUPTION POLICY: PAHARPUR BUSINESS CENTRE 13
in a manner suited/appropriate to the stated policy and rules of the
organization. It is expected that they will not only behave in an honest and
ethical manner but will also set a good example by acting in a responsible
and transparent manner.
• Are continuously conscious about and aim to
maintain our integrity, thereby maintaining
the integrity of the organization.
• All employees must adhere to this policy
and any violation to the above may result in
termination/legal action, as deemed �t by the
• The CEO must approve any exceptions to this
As owners of PBC, we:
• Commit ourselves to this policy, and to an
ongoing eﬀort to maintain our integrity.
• Make sure that PBC complies with national
regulation and commit PBC to an open and
transparent management approach.
• Expect our partners and other business
associates to respect this policy and wherever
possible we will in�uence them to also adopt
This article focuses upon the eﬀorts made by
Neyveli Lignite Corporation (NLC) to implement
the Integrity Pact, a tool developed by
Transparency International to help Governments
and Civil Society in �ghting corruption in
the Public Procurement Contracting. It also
describes the E-Procurement system and the
Online Integrated Material Management System
(OLIMMS) set up by NLC as part of their eﬀorts to
prevent corruption and encourage transparency
in their business dealings. The author points out
that the initiation of the new online system has
not only enabled them to curtail corruption but
has enabled them to shorten the procurement
E-Procurement at Neyveli Lignite Corporation
Neyveli Lignite Corporation was started in 1956. It is a Government of India
enterprise based in Tamil Nadu. NLC signed an MOU with Transparency
International India (TII) on 29.12.2007 for implementing the Integrity
Pact (IP) in the organization making it one of the pioneering companies
that voluntarily signed the MOU with TII even before the Chief Vigilance
Commissioner (CVC) issued guidelines for implementation of IP in PSU’s.
In NLC, Integrity Pact Program (IPP) covers the Tenders/Contracts value at
Rs. 1 crore and above, which is more that 90 percent value of the total
contracts/purchase executed by NLC. The IPP in the present form at NLC
has three players:
• The Principle (Govt. Companies)
• The Vendors/Contractors and
• The Independent External Monitors (IEMs)
A panel of three IEMs was proposed and accepted in 2008; their tenure as
IEMs at NLC has been extended up to Feb. 2013.
In keeping with the IPP, NLC has made the tender process in a transparent
manner by adopting the following activities, using its website and
• All tenders are hosted in downloadable format on the company
website since 2002.
• All the pre-bid clari�cations, outcome of the meetings are being
hosted on the website.
E-PROCUREMENT AT NEYVELI LIGNITE CORPORATION 17
18 E-PROCUREMENT AT NEYVELI LIGNITE CORPORATION
• Monthly reports of award of tenders are hosted on the website since
• LOA/Award of Contract and Return of EMD/Bid guarantee details
hosted since March 2007.
• All operations in connection with the purchase of spares such as
vendor registration for e-procurement, bid submission by e-tendering,
all tender processing by Material Management Complex through
OLIMMS (Online Integrated Material Management System) are done
online including the online sending of digitally signed purchase
orders (PO) to LI1
bidders. Each of these is detailed in the subsequent
After the implementation of the IPP, the following were done at NLC:
• Two meetings of the Vendors and Contractors with IEMs were
organized (on 06.10.2010 at Chennai and 07.10.2011 at Neyveli).
and Evaluation of IPP and its eﬀectiveness in NLC” (on 06.10.2010 at
Chennai, 09.06.2011 at Neyveli and 08.10.2011 at Neyveli).
• Steps have been taken to oﬀer the tendering process through e-
procurement for “Contracts” also. In connection with the same, an
order has been placed recently on IIT, Kharagpur.
Electronics Procurement (E-Procurement)
With the advent of the Internet in India in the late 1990s, individuals
and organizations started identifying ways and means of automating
The person/entity that has bid the lowest in a tender out of all the pre-quali�ed
bidders is called L1. Typically, the entire or the majority quantity/work is then
oﬀered to the L1 bidder. Where other qualifying bidders are also oﬀered part
of the quantity/work, they are then required to match the price and conditions
oﬀered by the L1 bidder.
E-PROCUREMENT AT NEYVELI LIGNITE CORPORATION 19
their key processes. E-Procurement (Electronic procurement) is one such
area, where the Internet was instrumental in automating the purchase
process, thereby signi�cantly reducing cost and time. E-procurement is
the integration and management of all procurement activities comprising
purchase request, �oating enquiries, submission of bids by the vendors,
clari�cations, price negotiation, evaluation and placement of order online
using Internet. Thus e-Procurement is the electronic B2B (or B2C or B2G)
sale and purchase of goods and services. The medium used might be the
Internet or any other media like EDI (Electronic Data Interchange) and
Enterprise Integrations (formerly known as EAI).
E-Procurement enables the user to introduce ease and eﬃciency without
provides transparency, results in saving of time and money, shortening
of procurement cycle as well as ease of operation to the implementing
organization and to the vendors. As per Government of India guidelines,
E- Procurement was introduced for the purchase of all items integrated
E-Procurement solutions enable organizations to automate their
purchasing process and reduce processing costs. With the web enabling
one of the critical areas of business process, organizations can now have
access to new strategic partners, uncover new suppliers and streamline
purchasing processes while simultaneously lowering the cost. Adopting
an e-procurement solution could save on the money, time and labour
that are normally wasted on sieving through reams of papers. While
implementing the e-procurement system captures approval routing,
it also captures data vital for creating more eﬀective strategic suppliers
management; moreover, it produces reports on product use and supplier
performances. Thus, the organization is rendered more eﬃcient and more
20 E-PROCUREMENT AT NEYVELI LIGNITE CORPORATION
productive. E-procurement aﬀords companies the opportunity to simplify
and streamline the purchasing processes, thus harnessing the power of
the web to ensure savings for the implementing organizations.
The e-procurement program was launched by NLC in 2007 using
software developed by IIT, Kharagpur to NLC speci�cations. Till date, 8202
enquiries have been �oated on 7785 purchase orders placed through e-
procurement. It was noted that the procurement lead time has reduced
drastically. Vendor enrolment too is increasing and around 1800 vendors
have enrolled through the e-procuremet package so far.
Types of Indents handled in Online Integrated Material Management
System (OLIMMS) are
• Regular Indent
• Price Agreement Indent
• Rate Contract Indent
The diﬀerent aspects of E-Procurement in the OLIMMS project at NLC are
Vendors who wish to participate in NLC e-procurement must necessarily
possess a class III Digital certi�cate with the name of the organization. An
online enrolment for participating in e-procurement is available on the
NLC website. The software automatically captures important information
such as the company name, address and email ID from the digital key
of the vendor. Vendors have to �ll in additional details and submit their
applications online. The application is then scrutinized by the vendor
registration cell before approving of the vendor enrolment. Following this,
E-PROCUREMENT AT NEYVELI LIGNITE CORPORATION 21
the system automatically generates an acceptance email and sends it to
the vendor at the email ID provided in the enrolment form.
All tenders, Limited Tender Enquiry (LTE), Short Tender Enquiry (STE) and
Press Tender Enquiry (PTE), are displayed on the main page of the NLC
website. Any vendor, whether registered or unregistered, can view any of
the tenders from here if they have Internet connection.
A checklist is automatically generated by the system irrespective of
the value of purchase. Details like enquiry number, enquiry method,
enquiry date, date on which the tender was opened, P.R.No., P.R. date,
number of enquires issued, whether the oﬀer was considered, number
of material, estimated value, total order value, total site cost, material
description, basic price, quantity, deviation, commercial terms, vendor
name and vendor code are automatically displayed by the system in the
The Dealing Assistant at the Purchase Department checks the �elds in the
enquiry and veri�es that all the requisite annexure as mentioned in the PR
are attached in physical copy. Addition/Deletion of the vendors can also
be done in the enquiry. Following this, an enquiry number is generated by
the system. The Dealing Assistant then submits the form, which is sent to
the approval cycle depending upon the enquiry value through work�ow
online. After approval from the competent authority, the Dealing Assistant
takes a print out of the enquiry and sends it to the vendors. At this time,
it is also automatically published on the website in PDF format and an
email alert is sent to the concerned vendors who have already enrolled
themselves in case of STE and LTE. In case of PTE marked for e-tendering,
the same is available to all vendors who are enrolled. The integrity of
22 E-PROCUREMENT AT NEYVELI LIGNITE CORPORATION
enquiries can be veri�ed by the vendors if required as these are digitally
The tenders are opened on the pre-determined date by Account and
Purchase Executives using their Digital Keys. All the quotations are
automatically decrypted by the application and available for further
processing. Simultaneously a copy of the quotation opened is published
on the website in the vendor’s homepage for the vendors to view.
Generation of Comparative Statement
For single cover system, price and techno-commercial comparisons are
made available as soon as the tender is opened. For two cover systems,
�rst the techno-commercial cover is decrypted and after cover one
success, the second cover is decrypted on the date speci�ed. In case of
press tenders, PQR and Techno-Commercial statement are made available
as soon as the cover is opened and the price statement is made available
after cover one success. All the statements are system generated and no
alternation/modi�cation/deletion is possible.
Clari�cations, both technical and commercial can be made through e-
procurement system for which vendors can give their response online.
Price negotiation/reduction can also be done through e-procurement
system online and replies obtained online. Classi�cation request, response
and negotiations are tracked by the system.
A digitally signed electronic purchase order is sent to LI vendors on
�nalization of the tender. The vendors have to acknowledge its receipt by
E-PROCUREMENT AT NEYVELI LIGNITE CORPORATION 23
email. Email alerts are sent automatically to the vendors at every stage to
the email ID given at the time of enrolment and a copy is marked to the
respective sections of the purchase branch.
All the documents starting from indent and inclusive of payment to vendor
require approval from Competent Authorities as per DOP. Approval of all
the documents in OLIMMS is carried out through the system itself and is
Director and the Board. The approval processes follow the prede�ned
work�ow sequence incorporated in the system. In case the approving
authorities require any modi�cation in the document, the document in
question is ‘rejected’ with corresponding remarks and sent back to the
initiator who then makes the necessary modi�cations and resubmits the
document for approval.
This agreement (Main Order) will specify that NLC will purchase materials
of speci�c value within the speci�ed period of agreement. After the
issue of main price agreement order, vendors can place any number of
suborders within the speci�ed value as mentioned in the agreement. The
agreement is generally entered for a period of one year. Both the main
order and suborder are generated through the system. Necessary checks
are built into the system so that suborders cannot be issued beyond the
main order value.
This agreement speci�es that NLC will purchase material on �xed rates
as mentioned in the main order within the duration of the agreement.
The rate contract is generally valid for one year. The main order contains
the delivery schedule of the suborders also. After the issue of main rate
24 E-PROCUREMENT AT NEYVELI LIGNITE CORPORATION
contract order, vendors can place any number of suborders indicating the
quantities required. Both the main rate contract order and suborders are
generated through the system.
Bene�ts of E-Procurement
The value proposition of an e-procurement solution includes expansion
of supplier base, better price negotiations and shorter procurement cycle
that help reduced inventories, clarity of speci�cation and adherence to
time frame. Other bene�ts include:
• Promoting competition among bidders
• Providing equitable treatment to bidders
• Promoting fairness and transparency in bidding oﬀers
• Eliminating face to face contact
• Publicizing bid information online, in real time
• Providing rich MIS and analytical data
Further, e-procurement system can be designed to factor in all rules and
orders on subjects such as:
• Rules relating to procurement
• Policy preference for PSUs/cottage and small industries
• Central Vigilance Commission Guidelines
• Comptroller & Auditor General Observations
• Delegation of Power
• Best International Practices
Last but not least, e-procurement holds the potential to free the
authorities from endless paper work and worries relating to inadvertent
non-compliance to above requirements.
E-PROCUREMENT AT NEYVELI LIGNITE CORPORATION 25
payment for buying and selling goods or services oﬀered through
Internet. Generally, electronic payment refers to online transaction on the
Internet; however, there are actually many forms of electronic payment. As
technology is developing, the range of devices and processes to transact
electronically continues to increase while the percentage of cash and
check transaction continues to decrease.
Implementing the e-procurement and e-payment system is not without its
challenges. The two biggest challenges are ensuring that the transactions
remain secure so that private information does not leak out and averting
could also prove to be a challenge. However, the scope of e-procurement
too is immense and the technology of e-payment, i.e. the payments of
�nes, citations, taxes, bills and rentals are already in place or are becoming
By implementing the Integrity Pact and the
E-Procurement systems, NLC ensures that all
tendering takes place in a fair and transparent
manner. This system further ensures that the
principles would not seek or accept any bene�t
from the bidders whilst making certain that
all bidders are treated with equity and reason,
thereby reducing corrupt practices.
Governance and Culture at
Tata Chemicals Limited
GOVERNANCE AND CULTURE AT TATA CHEMICALS LIMITED 29
Business at Tata Chemicals Limited (TCL) has
always been value-driven. TCL believes that
the importance of adhering to good Corporate
Governance cannot be emphasized enough. This
article outlines the Governance Policies at TCL
whilst discussing the formal as well as informal
systems and practices that have been put in
place to ensure ethical compliance.
Governance and Culture at
Tata Chemicals Limited
The foundations of Corporate Governance and a deeply embedded Tata
culture have helped Tata Chemicals Limited (TCL) to serve its stakeholders
and the society over the years. While Corporate Governance consists of
a framework of formal systems as well as policies and legal processes,
it is the organizational culture that acts as an enabler and supports the
governance systems in balancing the interests of various stakeholders.TCL
Culture, drawn from its core values (Integrity, Excellence, Safety, Care, and
Innovation), is re�ected in the way it conducts business, as also in the way
business environment. Leadership atTCL is committed to these values and
spends considerable time and eﬀort in communicating and reinforcing
these values across the organization and to relevant stakeholders.
Ethics and integrity are deeply rooted and widely shared values among
TCL employees while transparency, empowerment, accountability and
integrity are perceived as cornerstones for culture-building at TCL.
Governance Policies at TCL
corporate fairness, transparency, accountability and responsiveness. Such
policies focus on enhancement of stakeholder value with integrity, social
responsibility and compliance with the laws, thereby satisfying the law in
spirit and not merely in word.
Tata Chemicals Limited adheres to the principles of corporate governance
by consistently endeavoring towards improved operational performance
30 GOVERNANCE AND CULTURE AT TATA CHEMICALS LIMITED
through theTata Business Excellence Model and theTata Code of Conduct.
Please refer to Figure 1 for the guiding principles for Governance at TCL.
The �gure above enumerates the guiding principles for Governance in
the organization, which rests on Business Excellence Model and Code
of Conduct. The Board of Directors and Audit Committees form the
supporting mechanisms, by constituting various fora such as the Ethics
Committee. While these serve as supporting mechanisms, the onus of its
execution lies with both, the leadership as well as the employees, the roles
of each of which are described below.
The role of the Company Leadership covers the following:
• To make compliance a vital part of business activities.
• To establish and maintain the Company’s conduct of business in
accordance with the Code. Supervise compliance with the Code.
• Create a culture which promotes compliance, encourages employees
to raise their questions and concerns, provides for counselling and
Figure 1: Guiding Principles for Governance at TCL
GOVERNANCE AND CULTURE AT TATA CHEMICALS LIMITED 31
concerns and take prompt remedial action where required.
• To actively assist employees in all aspects related to understanding
and complying with the Code.
• To widely communicate all aspects of the Code and its management
to all employees.
The role of the Employees includes the following:
• Ensure personal and organizational compliance with the Code.
• Seek assistance from managers and other company resources with
regard to application of the code.
• To promptly report:
– Any concerns about violations of the Code
– Any concerns about likely possible violations of the Code
– Any concerns about a possible request to violate the Code
• Ensure that no retribution is meted out to anyone reporting or
supplying information about a concern.
At TCL, management practices and espoused values help employees
develop the ability to recognize ethical issues and respond to these in
a sensitive manner. Moreover, formal and informal systems are in place
for the Management of Business Ethics. All these combine to create an
environment and culture that supports and enhances ethical behavior
Formal Systems for Management of Business Ethics (MBE)
The governance structure is supported by a well-de�ned organization
structure and a comprehensive concern resolution mechanism (detailed
in a subsequent section of this document). The roles and responsibilities
32 GOVERNANCE AND CULTURE AT TATA CHEMICALS LIMITED
of each role holder is clearly de�ned and communicated. Moreover,
the Central Ethics Committee at Group Center provides guidance to
companies, formulates policies, guidelines and procedures, monitors
compliance within companies, address unresolved possible violations as
well as inter–company concerns.
The formal systems in place for the management of business ethics
comprise the following:
• Formal structure for deploying and enforcing ethical compliance
• Formal procedures for resolving ethical concerns
• Formal policies like a Gift Policy and the Whistle-Blower Policies
at the workplace
• Processes for engaging and disengaging dealers/distributors
• Regular programs to educate supply chain partners on the Tata Code
• Ethics-assurance surveys by third parties
• Direct access to leadership (Chairman, Principal Ethics Oﬃcer) to
• Mandatory induction on Ethics for newly joining employees
• Regular training and refresher courses for employees, suppliers,
dealers, contractors and customers.
– Annual declaration by the Managing Director to abide by the Tata
Code of Conduct
Management of Business Ethics (MBE) at TCL is embedded in all TCL
Activities and Initiatives as can be seen from Figure 2.
Tata Chemicals implements its MBE philosophy through a structure of
Figure 2: MBE in TCL Activities
GOVERNANCE AND CULTURE AT TATA CHEMICALS LIMITED 33
Principal Ethics Oﬃcer (PEO), Company Ethics Counsellors (CECs) and
Local Ethics Counsellors (LECs) as shown in Figure 3.
Principal Ethics Oﬃcer (PEO)
The PEO is also the Managing Director of the company. As the PEO, his
main chief responsibility is to ensure that the code of conduct is followed
not just in word, but also in spirit, whilst also ensuring the integrity of the
ethics reporting and monitoring system. To do so, the PEO is expected to
do the following:
Figure 3: Organizational Structure for Implementation of MBE
34 GOVERNANCE AND CULTURE AT TATA CHEMICALS LIMITED
Figure 4: Process for Handling Concerns
Key to the above chart:
Input to the process
Options at the process step
GOVERNANCE AND CULTURE AT TATA CHEMICALS LIMITED 35
• Set the tone of organizational integrity at the top
• Lead by serving as a role model
• Encourage ethical behavior by facilitating and legitimizing ethical
dialogue, appropriately selecting and placing ethics counsellors
• Allocate adequate resources and suﬃcient �exibility to the ethics
counsellors so as to enable them to eﬀectively undertake their
The PEO also ensures that the Ethics Counsellor have access to the
PEO, the Chief Financial Oﬃcer and the Board of Directors. The PEO is
also responsible for presenting the compliance report to the Board of
Location Ethics Counsellor (LEC)
The Location Ethics Counsellors (LECs) are a vital link between the
employees and PEO. LECs are drawn from existing TCL employees who
have a high degree of personal integrity, show respect for individuals,
display courage of conviction, demonstrate the ability to take stands and
maintain con�dentiality. Good listening and documentation skills are
also essential prerequisites for this role. The term of the LECs is usually
restricted to around two years so that more employees can be given the
opportunity to take on this role facilitating the development of leadership
qualities in them.
Concern Resolution Mechanism
A concern would include anything that reveals or indicates an actual
or possible violation of one or more of the 25 clauses of the Tata Code
of Conduct. The process for handling concerns is pictorially depicted in
Figure 4. Investigators who examine these concerns are selected based on
36 GOVERNANCE AND CULTURE AT TATA CHEMICALS LIMITED
their capabilities to work independently, impartially and analyse data in an
unbiased manner, maintain con�dentiality, timeliness, good listening and
documenting skills. Based on the �ndings of the investigation, appropriate
actions are initiated by the Principal Ethics Oﬃcer.
Informal Systems and Practices
Informal systems and practices comprise:
• Incorporate TCL Values and Tata Code of Conduct (TCoC) reviews
during meetings with supply chain partners
• Discuss on TCoC during business review meetings
• Leaders sharing experiences on ethics during communication meet
• Encourage employees and suppliers/customers to raise issues that
have ethical dimensions
• Openly encourage stakeholders to report ethical infractions that they
• Telling stories about the Tata Culture
• Transparency in dealing with employees and external agencies
• Embedding elements of the Tata Code of Conduct in all their policies,
processes and initiatives ranging from Aﬃrmative Action program,
CSR, Risk Management, to HR policies.
This judicious mix of formal and informal mechanisms have not only
helped in the consolidation of ethical values in TCL but have also aided
employee understanding of the same and ensured that they act in line
with values of integrity.
Ethics and Compliance for
The Siemens Experience
ETHICS AND COMPLIANCE FOR PROFITABLE BUSINESSES: THE SIEMENS EXPERIENCE 39
This article presents information on Siemens, a
multinational company that operates globally.
It traces the genesis of the Siemens Compliance
Guide for Anti-Corruption whilst highlighting
the salient features of the same. The author
points out that the Siemens experience is a
positive indication that businesses can be both
ethical and successful.
Ethics and Compliance for Pro�table Businesses:
The Siemens Experience
Siemens is a large multinational company that operates in over 190
countries and employs approximately 360,000 employees globally.
Siemens Ltd., in which Siemens AG holds 75 percent of the capital, is the
�agship listed company of Siemens AG in India. Siemens in India including
Siemens Ltd. comprises 13 legal entities, is a leading powerhouse
in electronics and electrical engineering with a business volume
aggregating about Rs. 12,000 crore. It operates in four business segments
– Industry, Infrastructure & Cities, Energy and Healthcare. Siemens has 21
manufacturing plants with well entrenched nation-wide sales and service
networks across India with close to 18000 employees.
Being responsible is one of the fundamental values that Siemens pursues
with the thrust being – “Only clean business is Siemens business”. The
company’s compliance system promotes fair practices within and outside
Siemens. The goal is to root out the menace of unscrupulous practices and
create a level playing �eld. In Siemens, compliance is far more than just a
program: it is the way Siemens does business. At Siemens, compliance is
seen as more than a business value, it forms the very backbone on which all
their operations are based and provides Siemens a competitive edge.This is
evidenced by a BusinessWorld survey in February 2011 where Siemens was
judged the“The Most Respected Company”in Engineering Sector in India.
Development of the Compliance Guide for Anti-Corruption
Ethics has always been a part of Siemens corporate philosophy with the
40 ETHICS AND COMPLIANCE FOR PROFITABLE BUSINESSES: THE SIEMENS EXPERIENCE
principles. He maintained: “I won’t sell the future for quick pro�ts”. For
decades, this formed the corner stone of all Siemens business practices.
Around six years ago, Siemens faced charges of corruption despite the
existence of policies to counter corruption. Siemens was accused of rigging
bids and indulging in corrupt practices to win contracts as part of a
the biggest markets in the world: USA and Europe. It also led to a great deal
of introspection within Siemens as to where things had gone wrong. Internal
investigations revealed that although Siemens had policies in place:
• These policies were not lived
• The corporate values were not incorporated
• The leadership had failed
Realizing this, the top management at Siemens swung into action. Their
action plan was implemented in three phases as shown in Figure 1.
Figure 1: Action Plan to Reduce Corruption and
ETHICS AND COMPLIANCE FOR PROFITABLE BUSINESSES: THE SIEMENS EXPERIENCE 41
The Culture of Compliance in Siemens
With a view to establishing a foundation of trust, four years back, eﬀorts
to build a Culture of Compliance started with the aim to build a reputation
recognizable for its rock steady integrity. For a company as large and
diversi�ed as Siemens, a strong code of conduct is essential to enable the
company to weather storms and attain greater heights. Today, Siemens
has developed a comprehensive Compliance System (detailed in the
subsequent section) which has proved to be very successful and eﬀective.
The company actively works with external partners to extend this policy
Compliance, at Siemens, is more than just a management principle. Over
the years, it has evolved into a way of life for Siemens employees. The
compliance system at Siemens is embedded in the company by a �rm
belief that compliance pays oﬀ economically. It therefore seeks to anchor
integrity more �rmly in the Siemens’organizational culture.
For a “culture of compliance” to work, it is important for every person
within the organization to make ethical business decisions and ensure
that his or her actions are consistent with the law and relevant Siemens
policies. This means understanding the policies and principles that
they represent. It also means that when a question or problem occurs,
people should respond with care rather than ignoring the issue or simply
guessing. However, a culture of compliance goes much further than that.
It means reporting concerns and making sure that suspect behavior does
not go unchallenged. Everyone needs to take compliance seriously and
encourage others to do the same. It is vital to follow the processes and
procedures for dealing with risky situations and involve the Compliance
Organization at an early stage when there are any problems. The mantra
followed is ‘When in doubt, ask!’ It also means making sure that every‘When in doubt, ask!’ It also means making sure that every‘When in doubt, ask!’
42 ETHICS AND COMPLIANCE FOR PROFITABLE BUSINESSES: THE SIEMENS EXPERIENCE
employee should make certain that his/her own record keeping and
documentation is accurate and complete. In general this means that every
procedures has been properly recorded and there are documents showing
the necessary approvals.
Compliance at Siemens is not just limited to internal employees.
Vendors, customers, contractors and business partners as well as external
stakeholders are integral to the business. Raising awareness through
training and education amongst these associates is a must in order to
ensure clarity amongst these groups on the Siemens approach to doing
business. To this end, Siemens collaborates closely with all its stakeholders
in order to initiate and foster fair business practices in all spheres of
business and beyond and to create and sustain a level playing �eld.
The following section highlights the salient features of the Siemens
The Siemens Compliance System
The basic principles of behavior are laid down in the Business Conduct
Guidelines. Additionally, Siemens has a number of policies that deal with
the most important areas of anti-corruption legislation. These policies
apply globally to the management and employees of Siemens AG and its
aﬃliated companies. The general principles and prohibitions also apply to
consultants and other third parties working on behalf of Siemens, as well
as suppliers, customers, business partners and others they do business
with. To ensure that these policies work properly across all business areas,
as well as to provide support and assistance for everyone, Siemens has
expanded its Compliance system.
ETHICS AND COMPLIANCE FOR PROFITABLE BUSINESSES: THE SIEMENS EXPERIENCE 43
The current Siemens Compliance System was developed in 2007 and 2008
and the global compliance organization engages around 600 employees
worldwide and gaining experience in this function is seen as an important
part of career development. The Siemens Compliance System aims at
as shown in Figure 2. At Siemens, the principle “Tone from the Top” that
focuses on management, especially middle management, is very crucial
for the success of compliance. In keeping with this principle, the entire
management is expected to ensure that these processes and procedures
are applied in a consistent manner, and that their spirit is embraced in
the day-to-day business across all Siemens companies. The intention is
to prove that actions do speak louder than words. Mr. Peter Loescher, the
Global CEO, believes that “Compliance as part of corporate responsibility
is our �rst priority.”
At Siemens, the anti-corruption policies apply to both the public and the
private sectors. However, because the risks are diﬀerent, their compliance
policies, procedures and controls sometimes make a distinction between
the public and the private sectors.
Various activities are undertaken as part of the ambit of Compliance
System. Siemens’ business values aim at attaining highest levels of
performance whilst maintaining the highest ethical standards. To achieve
this, Siemens’ business conduct guidelines are simpli�ed and integrated
into the business processes. In order to safeguard the company, Siemens
has formulated various compliance related policies like High Risk Payment,
Gift & Hospitality and dealing with business partners.
Siemens has also formed a Compliance Help Desk, to assist in prevention
and detection of the non-compliant conduct. It works as a platform for
the employees to get information and to give feedback and suggestions.
Figure 2: Pictorial Representation of the Siemens
44 ETHICS AND COMPLIANCE FOR PROFITABLE BUSINESSES: THE SIEMENS EXPERIENCE
‘Ask Us’ and ‘Tell Us’ functions are a part of the services oﬀered by the
Compliance Help Desk.
The ‘Ask Us’ function enables an employee to ask detailed, speci�c
questions regarding Compliance, with an assurance of receiving an answer
from experts. Employees who are not sure how a particular policy should
be applied in practice can also avail of this function.
The ‘Tell Us’ function enables an employee to inform the management
regarding the breaches of Business Conduct Guidelines. It is a 24 hour
Whistleblower hotline, operated by a third party and available in 150
The compliance investigation department assesses misconduct following
an oﬃcial investigation. In addition Siemens has devised a global
case tracking tool to improve its information �ow regarding potential
Siemens adopts ‘Zero Tolerance’ towards compliance violations. This
sanctions are awarded as an outcome of the investigation and can include
either of the following depending on the severity of the case:
• Informal warning (slight compliance violations only)
• Formal warning which impacts the earnings
• Separation from the organisation
The disciplinary process may be invoked at the central or the local level,
depending on the level of the oﬀender and the nature of the oﬀence. Every
employee who commits a compliance violation will have to complete
remediation compliance training.
ETHICS AND COMPLIANCE FOR PROFITABLE BUSINESSES: THE SIEMENS EXPERIENCE 45
Other Compliance Related Activities
Siemens India has embraced the “Integrity pact” concept, which
Transparency International developed to prevent corruption in public
procurement context and which has been strongly advocated by the
Central Vigilance Commission, India.
Siemens, as a part of the Global settlement with World Bank, supports
Siemens has provided a grant of US$ 4.35 million over 4 years to the United
Nations Global Compact Project to promote Collective Action against
corruption in key markets, including India.
The compliance department at Siemens imparts regular trainings [in
person as well as Web based training] to their employees at all levels. New
recruits sign the BCG [Business Conduct Guidelines] forms and are trained
within 6 weeks of joining. Middle and senior managers are regularly
nominated for the Residential Seminar on ‘Heart of Eﬀective Leadership’
conducted by Initiative of Change.
with other business groups and organizations such as Tata Group of
Companies; Transparency International, India; Confederation of Indian
Industries; Indian Electrical and Electronics Manufacturers Association;
Indo German Chamber of Commerce; Global Compact Network, India
and United Nations Oﬃce of Drug and Crime to share and learn the best
with some of the leading industrial and corporate houses to promote fair
business practices. Please see Figure 3.
Being ethical has enabled Siemens to achieve
success in the following ways:
• Employees: Decision making becomes easier
with well de�ned policies that guide them
through challenging situations
• Vendors: Transparency in dealings with
vendors provides Siemens a competitive edge
• Customers: Customers feel more comfortable
dealing with Siemens
• Growth: The business �gures of the company
show stupendous pro�table growth
• Shareholders: Siemens is now ranked no 1 in
Dow Jones Sustainability World Index.
46 ETHICS AND COMPLIANCE FOR PROFITABLE BUSINESSES: THE SIEMENS EXPERIENCE
Figure 3: A diagrammatic representation of the collaborative partners
ETHICS AND COMPLIANCE FOR PROFITABLE BUSINESSES: THE SIEMENS EXPERIENCE 47
The rewards and accolades of being compliant are numerous. A major
customer invited Siemens’ compliance oﬃcer to discuss the company’s
anti-corruption initiatives during its recent tendering process. Siemens
India participated in bidding and won a US$ 68 million order.
In June 2011, a consortium led by Siemens won a US$ 4.7 billion
government contract to build carriages for the UK’s Thameslink upgrade
program. In September, the Swiss Federal Railway selected Siemens Rail
Automation for a 125 million contract to update the Swiss rail network’s
safety technology over the next 6 years. Overall the value of US public
contracts awarded to Siemens has risen by 20 percent.
In conclusion, Siemens is a company which believes that business can be
Ethical and Successful, as opposed to having to choose between Ethical
or Successful. Its business practices in the past six years have proved this
belief whilst making the name Siemens synonymous with clean business.
Anti-Corruption and Anti-Bribery
Practices in Tata Steel
ANTI-CORRUPTION AND ANTI-BRIBERY PROGRAM: ENLIGHTENING PRACTICES IN TATA STEEL 51
Tata Steel has been following ethical business
principles and practices since the time of its
inception. However, these principles were not
documented but were followed as an article of
faith by successive leadership of the company;
in other words these were unwritten laws. These
principles were articulated and documented
for the �rst time in 1998 in the form of the Tata
Code of Conduct. This article focuses on the
diﬀerent policies and programs developed to
curtail corruption and create an appropriate
anti-corruption and anti- bribery environment
across the company.
Anti-Corruption and Anti-Bribery Program:
Enlightening Practices in Tata Steel
Established in 1907, Tata Steel is one of the top ten global steel companies
with an annual crude steel capacity of over 28 million tonnes per annum
(MTPA) with an annual turnover of around US$ 22.8 billion (FY2010). It is
now one of the world’s most geographically-diversi�ed steel producers,
with operations in 26 countries and a commercial presence in over 50
countries employing over 80,000 people across �ve continents.
The Tata Group is one of the �rst groups in India to have developed a
written code of conduct that was adopted by all the group companies.
The Tata Code of Conduct which was formulated in1998 emerged after
a lot of deliberations and interactions at the senior management levels
of the diﬀerent companies in the Tata Group. The TCoC was essentially
India centric in application and re�ected the Core Values of the Company
which focused on the creation and sustenance of ethical culture in the
organisation. Tata Steel adopted the TCoC in the same year that it was
declared and all oﬃcers employed at Tata Steel were asked to sign the
Code of Conduct compliance statement. The business values held by the
these included integrity, respect for individual, credibility, trusteeship and
excellence; all of which emerged from employee suggestions. The values
and TCoC are available on the website as well as intranet of the company.
However, the structure of the group changed by 2008 with the company
developing a global presence and it was felt that Code of Conduct
needed to re�ect this change and focus on globally important issues
52 ANTI-CORRUPTION AND ANTI-BRIBERY PROGRAM: ENLIGHTENING PRACTICES IN TATA STEEL
like personal accountability for implementing the Code, anti-corruption
measures, ensuring diversity and equality within the workplace as well as
safeguarding human rights and prevention of violation of the same in the
workplace. This led to a revision of the Code in the year 2008 and the new
Code was released by the Chairman on 1st October 2008.
Provisions in the new Code that relate to compliance and anti-
While the Company has always followed a policy of zero tolerance for
unethical conduct, the revised Code provided an increased focus on issues
related to bribery and corruption whilst creating an appropriate anti-
bribery and anti-corruption culture.
Speci�c sub clauses were added to the 2008 Code on anti-bribery and anti-
corruption measures. These measures were inducted and re-emphasised
in the following clauses:
• Clause 2 relates to �nancial reporting and records. It made a de�nite
statement that“no employee shall make, authorise, abet or collude in
any improper payment, unlawful commission or bribing”.
with Government authorities in eﬀorts to eliminate all forms of bribery,
fraud and corruption”.
• Clause 6 covers interactions with Government agencies: “A Tata
Company and its employees shall not, unless mandated under
applicable laws, oﬀer or give any company funds or property as
donation to any government agency or its representative, directly or
of oﬃcial duties. A Tata company shall comply with government
procurement regulations and shall be transparent in all its dealings
ANTI-CORRUPTION AND ANTI-BRIBERY PROGRAM: ENLIGHTENING PRACTICES IN TATA STEEL 53
with government agencies.” This clause focuses on issues related to
corruption and bribery in connection with Government agencies
and articulates the commitment of the company to prevent such
• Clause 13 deals with third party representation: Constantly increasing
services and activities oﬀered by the company entail engagements
with third parties. The inclusion of this clause ensures that third party
agreements are also brought within the ambit of the Code. Moreover,
with the values and Code of Conduct of the Company. This clause
implies that the company has zero tolerance towards unethical and
corrupt behaviours exhibited by any third party.
to bring in the element of transparency and integrity. It also serves to
demonstrate high moral and ethical standards of the employees, both
actual and perceived. Further, this clause ensures that employees do
not indulge in bribery and corrupt activities.
• Clause 20 relates to con�ict of interests: This clause makes obligatory
for employees to report con�ict of interest situations.
• Clause 25 centres around reporting concerns: This clause includes
stipulations on the implementation of Whistle Blower mechanism for
employees as well as for vendors and partners. It also provides advice
for the engagement of third parties for whistle blower to ensure the
independence of the reporting management system.
Implementation of anti-corruption measures
The company has taken the actions detailed in the subsequent paragraphs
to implement the above anti-corruption measures.
54 ANTI-CORRUPTION AND ANTI-BRIBERY PROGRAM: ENLIGHTENING PRACTICES IN TATA STEEL
• Diﬀerent Business Units of the company were subject to risk analysis to
identify their risks related to corruption. The following measures were
taken as steps to mitigate risks related to corruption and bribery:
– A Memorandum of Understanding (MoU) was signed with Tata
Workers Union and FAMD (Ferro Alloys & Minerals Division)
Employees Union wherein the unions reaﬃrm their commitment to
comply with the Code. This ensured that all unionised employees
reiterated their commitment to anti-corruption and ethical
• The company organizes a‘Celebration of Ethics Month’with dedicated
ethical themes to engage employees and other stakeholders in anti-
corruption and code compliance measures.
• A departmental ethics coordinatoris nominated by the respective
HOD to implement the code all across the organisation and involve
local management in the business ethics implementation. Further,
the criteria for selection of the Departmental Ethics Coordinators was
developed and circulated to all the business leaders.
• A Gift Policy was developed and publicised. Moreover, a system
for declaration of gifts received, if above the value permitted, was
• The processes detailed in the con�ict of interest declaration statement
were re-evaluated and it was decided that a new system of intranet
based COI (Con�ict of Interest) declaration would be developed and
implemented in the year 2011-12. It was also decided that the new
system would have clear cut de�nitions of relatives, family members
ANTI-CORRUPTION AND ANTI-BRIBERY PROGRAM: ENLIGHTENING PRACTICES IN TATA STEEL 55
be issue of Con�ict of Interest. For this purpose, global benchmarking
practices will be examined and adopted suitably.
• A third party whistle blowing line was developed.The whistle blowing
system was evaluated and it was decided that a third party whistle
blower policy was required to foster con�dence among the stake
holders and ensure them of con�dentiality. This policy has been
implemented from 1st July 2011.
As stated above, all oﬃcers across the company have signed the Code of
Conduct compliance statement making them accountable for complying
with the anti-corruption measures.
All newly appointed employees undergo a training programme that
orients them on theTata Code of Conduct compliance. During the training
programme, emphasis is laid on the clauses that relate to anti-corruption
The induction training programme also contains a capsule on Vigilance,
which is conducted by the Vigilance Department. As part of this
programme, the various misconducts in the area of vendor management
and other corruption prone areas are discussed in detail. The aim of this
training programmes is to orient the trainees and make them aware of
the types of corrupt activities that may go on in the organisation whilst
suggesting strategies that would enable them to catch the culprit.
Action taken in response to incidence of corruption
Tata Steel has a vigilance cell at the corporate level which reports
to Principal Executive Oﬃcer (PEO) of Tata Steel. It is headed by an
experienced executive and the team comprises around 10 oﬃcers. On
receipt of a speci�c concern from any stakeholder or from any executive,
Compliance to Code of Conduct is a condition
to service for all newly appointed employees
at all levels, inclusive of officer and non-officer
categories; appropriate stipulations are made
in the appointment letters.
56 ANTI-CORRUPTION AND ANTI-BRIBERY PROGRAM: ENLIGHTENING PRACTICES IN TATA STEEL
the cell conducts a thorough investigation on the matter and submits
their �ndings to the PEO. Based on the �ndings, further action, as deemed
�t, is taken in consultation with the concerned agencies. The group also
conducts training programmes for employees to make them understand
the various forms of misconduct that can take place in the organisation
and decide the proactive actions that need to be taken by them.
Since the company has zero tolerance towards corruption and unethical
activities, all such reported cases are investigated thoroughly by the
Vigilance Department and based on the �ndings of the enquiry further
disciplinary measures are taken against the violators, both employees as
well as the vendor.
ANTI-CORRUPTION PRACTICES AT INFOSYS LTD. 59
This article provides an overview of the
anti-corruption practices followed by Infosys
Limited (“Infosys”) to ensure good governance.
Infosys believes that good performance and
good governance are cornerstones of success
and eﬀorts are made to ensure that these are
part of business practices across the board. The
Infosys Code of Conduct and Ethics and the
Values Training Program enable the organization
to ensure that all employees assimilate
corporate and business values and practice it in
their daily work-life.
Anti-Corruption Practices at Infosys Ltd.
Infosys Limited (NASDAQ: INFY) was started in 1981 by seven visionaries
with US$ 250.Today, the company is a global leader in the next generation
of IT and Consulting with revenues of over US$ 6.99 Billion. Their oﬀerings
span business and technology consulting, application services, systems
integration, product engineering, custom software development,
maintenance, testing, independent validation services, IT infrastructure
services and business process outsourcing. Infosys operates globally
from 77 cities, 32 countries with over 150,000 employees representing 89
nationalities. Infosys became a member of the Global Compact Network
(GCN) in 2007.
The Infosys credo can be summed up in the following statement by Mr. N.
R. Narayana Murthy, Chairman Emeritus, Infosys Limited:
“Communicate your vision, not just by articulation, but by living it.”
the vicissitudes of global business environments over the decades. Setting
the‘tone’with role-model leadership right from the top and across various
levels in the organization, Infosys is supported by an eﬀective governance
framework, strong risk management practices and associated processes.
Infosys has won a number of awards for Corporate Governance till date.
Some of them are:
• Ranked No. 1 in all 4 categories – Best Investor Relations website, Best
Online Annual Report, Best Financial Disclosure and Best Corporate
Governance Practices at the 2011 IR Global Rankings in India.
60 ANTI-CORRUPTION PRACTICES AT INFOSYS LTD.
• Ranked among the best in investor relations in the APAC region in
• ‘Best investor relations by an APAC company in the U.S. market’at the
IR Magazine U.S. Awards in 2008.
• Ranked India’s‘Most Admired Company’inTheWall Street Journal Asia
• Recognized as India’s best company for corporate governance: Asia
money in 2005.
• Awarded the Platinum Award in The Asset Corporate 2010 Awards.
Please refer to our website www.infosys.com for more information on awards.
Eﬀective Corporate Governance Processes at Infosys
1. A Strong Leadership and an Independent Board
The current policy is to have an appropriate mix of executive and
independent directors to maintain the independence of the board and
to separate its functions of governance and management. Currently the
board consists of 15 members, six of whom are executive or full time
directors while the remaining nine are independent directors. The Board
periodically evaluates the need for change in its composition and size.
All committees of the Board consist of only independent directors. The
composition of the Board is carefully planned to ensure the presence
of diverse perspectives that facilitate debate and dialogue on issues
important to the corporation. In addition, the roles of the Chairman of the
ANTI-CORRUPTION PRACTICES AT INFOSYS LTD. 61
Board and the CEO are separated to ensure that the Board always retains
the right focus in keeping with the belief that:
“Good governance cannot be imposed by legislations. It must come from
within. Hence the Board, at the apex of the company’s corporate governance
structure, is the key.”
2. Transparency, fairness and accountability
Infosys has always followed the highest levels of disclosure to all its
stakeholders. The old adage, ‘When in doubt, disclose,’ is a management
practice at Infosys. The company has also integrated strong processes
into their supply chains to ensure the percolation of these processes into
the businesses of their partners. In addition to ensuring compliance with
the laws of the land wherever they operate, Infosys also has a very strong
Code of Conduct and Ethics. Some of Infosys’ best practices in this space
include benchmarking corporate governance and this is done through
Standard & Poor’s, ICRA and CRISIL. Infosys is the �rst company in India
to be awarded the highest Corporate Governance Rating (CGR) by ICRA.
Infosys also furnishes updates in extensible Business Reporting Language
(XBRL) format to the US Securities and Exchange Commission. Further,
their �nancial statements are disclosed in accordance with the Indian
GAAP, IFRS and US GAAP requirements.
3. Enterprise Risk Management
Enterprise Risk Management (ERM) at Infosys encompasses practices
relating to identi�cation, assessment, monitoring and mitigation of
various risks to key business objectives. ERM at Infosys seeks to both
minimize adverse impact of risks on their key business objectives and
to enable the company leverage market opportunities eﬀectively. The
corporate scorecard enunciates key business objectives through a set of
62 ANTI-CORRUPTION PRACTICES AT INFOSYS LTD.
speci�c goals to be achieved in the short term and strategic goals aimed
at achieving their aspirations in the medium term. Business objectives at
Infosys typically include goals relating to dimensions such as Financial,
Client & Market, Operational excellence and Talent & Leadership. There
are linkages between risks and key business objectives. Several risks can
impact the achievement of a business objective. Similarly, one risk can
impact the achievement of several business objectives.
Further, risk management practices at Infosys seek to sustain and enhance
long term competitive advantage of the company. Risk management
is integral to the Infosys business model, described as ‘Predictable,
Sustainable, Pro�table and De-risked’(PSPD) model. Their core values and
ethics provide the platform for their risk management practices.
4. Enhancing the ethical judgment of employees
Ensuring that the principles of good governance are translated into action
by employees on a daily basis is critical in building an ethical organization.
task. A strong and well articulated Code of Conduct and Ethics (which
also delineates Anti-Bribery provisions) and a Values Training Program
(detailed in the subsequent section) have been put in place to achieve
good governance.This coupled with multiple redressal mechanisms which
include a grievance redressal body and a whistleblower policy, constitute
a robust eco system for good governance practice.
The Code of Conduct and Ethics is intended to establish and clarify
ethical conduct, and a safe and secure workplace free from discrimination.
It articulates compliance with applicable laws of the land, and principles
such as promoting free and fair competition and the handling of apparent
ANTI-CORRUPTION PRACTICES AT INFOSYS LTD. 63
or actual con�icts of interest. The Code of Conduct also includes provisions
relating to anti-corruption, anti-bribery and lays down stringent norms for
the protection of con�dentiality of Infosys information. Demonstrating
Infosys’s commitment to the business ecosystem, the Code of Conduct
and Ethics also sets out their responsibilities towards their suppliers and
customers. Infosys recognizes the rights of their employees and provides
forums, support groups and policies to hear and address their concerns
and resolve issues or con�icts in a fair and transparent manner. The Code
of Conduct together with a robust grievance redressal process including a
whistleblower policy forms the bedrock of the organization’s governance
The whistleblower complaint mechanism was adopted by Infosys as part
of the guidelines set out under the US laws including the Sarbanes Oxley
Act of 2002 (SOX). The whistleblower mechanism is meant to address
concerns relating to (i) questionable accounting, accounting controls,
auditing matters, or reporting of fraudulent �nancial information to our
i.e., conduct which results in a violation of law by the Company or in a
substantial mismanagement of Company resources which if proven,
would constitute a criminal oﬀence or reasonable grounds for dismissal of
the person engaging in such conduct; or (iii) conduct which is otherwise
in violation of any law. This law is applicable to Infosys as a Foreign Private
Issuer listed on the NASDAQ.The framework was decided keeping in mind
the best practices being advocated for SOX compliance and developed
this policy based on feedback from their legal counsels.The framework for
the whistleblower mechanism emerged after a discussions and meetings
with the external counsels, Board committees-the audit committee in
particular as it is the oversight committee under the SOX for whistleblower
64 ANTI-CORRUPTION PRACTICES AT INFOSYS LTD.
complaints. It took about three to �ve months to implement this across
the organization. People involved in the design and development of this
framework included Infosys lawyers, internal compliance teams, auditors,
senior management and Board of Directors.
to employees across the globe through training and awareness programs,
both online and instructor-led, using multiple learning media including
leader talks, contests, blogs, portals, and a popular ‘Do you know’ series
that ensures updated information at regular intervals. The internal
communications team at Infosys periodically sends out communication
mails to employees familiarizing them with the provisions of the Code
of Conduct document. These mails also illustrate aspects of the Code of
Conduct through relevant examples.
It is mandatory for every new employee to attend sessions on the
‘Infosys Values’ as part of the induction process and then sign her/his
acceptance of the code of conduct. Every employee is then expected to
put these values into practice on a daily basis through his career with
The Infosys Values Program
Keeping in mind the various business risks associated with ethical non-
compliance, the Infosys Values Program seeks to:
• Reinforce the practice of Infosys values among employees,
• Enable a uniform understanding and application of the Infosys
• Create a climate of discussion, debate and engagement regarding
Infosys values and their practice,
The Infosys Values Program aims to: Create
awareness amongst employees on the Infosys
values; Establish for a to translate the espoused
values from a pulpit of preaching to actual
practice through employee engagement,
debate and discussion; and Develop enablers
by way of training, development and other
ANTI-CORRUPTION PRACTICES AT INFOSYS LTD. 65
• Develop enablers in terms of training, pre-reads, self-learning modules,
• Create a cycle of feedback and analysis to equip the new hires
(experienced personnel as well as fresh graduates newly employed by
the company) with an understanding of the Infosys values.
The InfosysValues Program has three diﬀerent aspects to it, each targeting
a diﬀerent group:
• Employees (Current)
• New hires
its training and marketing collaterals (posters, portal, mailers)
– Completed a survey of senior leadership (Tier Leaders Survey)
– Engaged employees in various events (Photograph Contest, NRN
& I contest, Poster Contest, Story Contest) to spread the message of
– Rolled out debate and discussion forums (Discussion Board, Sparsh
(Infosys Intranet), InfyTV)
– Created a CLIFE (Customer Value, Leadership by example, Integrity,
Fairness and Excellence) Booklet
– Completed a dipstick survey for senior leadership (Tier Leader
– Strengthened Training and Marketing collaterals (posters, portal,
– Made values adherence aspirational through the introduction of a
Values Champions category in the highest award in the company, viz.,
Awards for Excellence.
“CLIFE helps me drive towards customer
advocacy. I have learnt that you can achieve
that in two ways, viz., by delivering beyond
expectations and by delivering beyond
expectations consistently in every transaction.”
– Haragopal M.
66 ANTI-CORRUPTION PRACTICES AT INFOSYS LTD.
Details of projects initiated under the CLIFE program are given below:
A. Tier Leaders Values Survey: The purpose of this survey was to
poll senior leaders within the organization on their personal values
vis-à-vis organizational values. The survey aimed to strengthen the
correlation of personal and organizational values and also discuss
potential gaps, if any, with a view to bridge them. In-depth tele-
interviews were conducted by trained HR interviewers with forty �ve
Tier Leaders across the organization.The structured interview focused
on the following areas:
a) Alignment between personal and professional values;
b) Exploration of values-con�ict; and
The results of this survey indicated that CLIFE is indeed an enabler
which drives alignment between personal and organizational values
and oﬀers a framework that employees can refer to when faced with a
The survey also pointed out some challenges in continuous
communication of values throughout an ever growing employee pool
across geographies. While some things could be measured, a lot of
values data de�ed measurement. The penal route was one used to
drive ethical behavior.
The survey led to many initiatives that helped the organization:
a) Drive values awareness in order to minimize instances of
transgression/breach of values;
b) Plan the creation of a values awareness index for employees; and
c) Strengthen tracking of values training compliance across