The document discusses preventive vigilance and building a new corruption-free India. It provides Gandhi's views on corruption including his 11 vows with a focus on non-stealing. It outlines the three types of vigilance functions and emphasizes the importance of preventive vigilance through monitoring vulnerabilities and threats, implementing controls, and sensitizing staff. Analysis of top bank fraud cases by CVC and preventive measures like job rotation and internal controls are mentioned. The challenges of using preventive vigilance to increase organizational happiness and stakeholders' confidence are also noted.

1. Vigilance Awareness Week
2018

2. Theme
• Eradicate Corruption – Build a New India
• Vision of New India to be achieved by 75th anniversary of our
Independence i.e. 2022
• NITI ( National Institution for Transforming India) Aayog has released
blue print of New India
• A quote from PM’s message:
Dr. N. N. Nigam

3. New India Movement 2017-2022
• Sankalp Se Siddhi (New India Movement 2017-2022)
• By 2022 we build a New India
• Corruption Free India
• Clean India
• Poverty Free India
• Terrorism Free India
• Casteism Free India
• Communalism Free India
• Let us all strive in spirit and soul to accomplish this pledge for building a
New India.
Dr. N. N. Nigam

4. What is corruption?
• The simplest definition is:
• Corruption is the misuse of public power (by elected politician or appointed civil servant) for private gain.
• In order to ensure that not only public corruption but also private corruption between individuals
and businesses could be covered by the same simple definition:
• Corruption is the misuse of entrusted power (by heritage, education, marriage, election, appointment or
whatever else) for private gain.
• This broader definition covers not only the politician and the public servant, but also the CEO and
CFO of a company, the notary public, the team leader at a workplace, the administrator or
admissions-officer to a private school or hospital, the coach of a team, etc.
• A much more difficult, scientific definition for the concept ‘corruption’ was developed by Profesor
(emeritus) Dr. Petrus van Duyne:
• Corruption is an improbity or decay in the decision-making process in which a decision-maker consents to
deviate or demands deviation from the criterion which should rule his or her decision-making, in exchange for
a reward or for the promise or expectation of a reward, while these motives influencing his or her decision-
making cannot be part of the justification of the decision.
• A framework for deducing mens rea.
Dr. N. N. Nigam

5. Gandhian View and Approach
Dr. N. N. Nigam

6. The 11 vows of Gandhiji
• Gandhiji first declared his 11 vows when he established his first Ashram in
India, Kochrab Ashram, in 1915.
• Only those were admitted as inmates to the ashram, who were ready to
take these vows.
• The 11 vows were like 11 steps to higher awareness, higher realisation
and higher attainment.
• Satya or Truth,
• Ahimsa or nonviolence,
• Brahmacharya or celibacy,
• Asteya or nonstealing,
• Asangraha or nonpossession,
• Sharir Shram or bread labour,
• Aswada or control of palate,
• Bhayavarjana or fearlessness,
• Sarva Dharma Sambhav or religious equality,
• Swadeshi or use of local products, and
• Sparsh Bhavana or removal of untouchability.
Dr. N. N. Nigam

7. Asteya (non stealing)
• Asteya is not a limited practice of not stealing as a direct action.
• The indirect and subtle ways of stealing, like
• lying stealing of truthfulness,
• cheating stealing others’ rights,
• conspiring stealing of others’ legacy,
• waging of war stealing of others’ territories, these are also forms of stealing.
• Gandhian thoughts
• Mankind’s greed and craving for artificial needs are also stealing
• When we compound our needs and wants, we actually steal from others’ right to basic
requirements.
• A wealthy man residing in a mansion steals a poor man’s land for his hut.
• Gandhiji has written in Yerawada Mandir, “One who follows the observance of Nonstealing
will bring about a progressive reduction of his own wants. Much of the distressing poverty in
this world has risen out of the breaches of the principle of Nonstealing”.
Dr. N. N. Nigam

8. Restraints prescribed by Sage Patanjali
• The five yamas listed by Patañjali in Yogasūtra 2.30 are:
• Ahiṃsā (अह िंसा): Nonviolence, non-harming other living beings.
• Satya (सत्य): truthfulness, non-falsehood.
• Asteya (अस्तेय): non-stealing.
• Brahmacharya (ब्रह्मचयय): chastity, marital fidelity or sexual restraint.
• Aparigraha (अपरिग्र ः): non-avarice, non-possessiveness.
Dr. N. N. Nigam

9. VIGILANCE FUNCTIONS
a. Punitive Vigilance
b. Detective Vigilance
c. Preventive Vigilance
The above order of (a) to (c) is traditional approach.
“Right Approach” is (c) to (a)
Dr. N. N. Nigam

10. • In an organisational setup “VIGILANCE” connotes
“being watchful in day to day transactions in line with
the laid down systems and procedures”
• Vigilance is an “integral part of managerial function”
• ‘preventive vigilance’ functions, he( RBI Governor in
his recent lecture at CVC) said this approach inculcates
a sense of honesty and integrity among its employees
and ensures that sound internal systems and controls
are laid down, which act as a defence against intended
malafide activity by an employee.
PREVENTIVE VIGILANCE
Dr. N. N. Nigam

11. PREVENTIVE VIGILANCE
Some Positive Dimensions
i. Is people oriented.
ii. Sensitises people.
iii. Protects people.
iv. Aims at reducing/eliminating the “OPPORTUNITIES” to
fraudulent people.
v. Avoids cost involved in detective and punitive vigilance
functions.
vi. Saves people from unpleasantness of detective and
punitive vigilance functions
vii. Ensures that Organisation is on right path for achieving
the set Goals
Dr. N. N. Nigam

12. Basic Conceptual Tools
• Vulnerabilities
• Systemic
• People – both inside the organization as well as outside
• Threats
• Environmental
• People - both inside the organization as well as outside
• Risks
• Probabilities of Threats exploiting Vulnerabilities
Dr. N. N. Nigam

13. Instrumentalities for Preventive Vigilance
• Constant monitoring of environment
• Lessons from previous ‘incidents’ to be internalised
• Periodic Preventive Committee Meetings
• Committee should have representation of all stake holders – management,
employees, customers, suppliers and any other related entity
• The minutes to be acted upon effectively
• IT Systemic controls
• Process controls
Dr. N. N. Nigam

14. ISSUES
• Sensitising staff about the threats
• Developing culture of Preventive vigilance
• Enabling staff to identify the vulnerabilities
• Linking vulnerabilities to the threats
• Identifying appropriate controls
• Evaluation of controls
• Monitoring of controls
• External as well as internal environment is dynamic
Dr. N. N. Nigam

15. Analysis of Top 100 Bank Frauds by CVC
• In view of the alarming rise in Bank frauds, the Central Vigilance
Commission has undertaken a review and analysis of top 100 Banks
Frauds, as on 31.03.2017.
• The analysis focused on the loopholes that facilitated perpetration of
concerned fraud and systemic improvements required to plug the
loopholes in the system & procedures, etc.
• The full report is available on CVC web site.
• Similar exercise should be undertaken for other categories like smaller
value loans, specific region etc. to identify preventive measures.
Dr. N. N. Nigam

16. Some Preventive Measures
• Rotation of Jobs
• Wednesday, January 19, 2011
• 10 days vigilance leave for SBI employees
• INTERNAL CONTROL & HOUSE-KEEPING MECHANISMS IN BANKS
• "Internal Control system is one wherein the accounting work of the employee
is complemented and verified by the work of another employee – both the
employees working independently and without duplication of each other's
work".
• Scrutiny of Documents/vouchers of Computer based transactions
Dr. N. N. Nigam

17. Challenges for Preventive Vigilance
• Can it be used to increase overall ‘happiness content’ of an
organisation
• Customer delight
• Depositors
• Borrowers
• Topline
• Bottomline
• Brand value
• Welfare of employees
• Confidence of stake holders
Dr. N. N. Nigam

18. Thank you.
Dr. N. N. Nigam
Ex DGM (Vigilance), State Bank of India
nnnigam@yahoo.com
Dr. N. N. Nigam