Corporate integrity system compliance training 2017

1. Corporate Integrity System (CIS)
Ms. Sophia Aspesi Areias, Business Integrity Programme Manager
Transparency International Cambodia

2. 2
Content
CPI
GCB
BIP
CIS

3.  BIP initiated in January 2014
 Global movement
 Regional network
 What We Do
 Corporate integrity System
 Services/Trainings on for example the legal framework, taxation,
procurement, public service fees and anti-bribery principles
 Research – SME Corruption Perception, Case Study on Taxation
 General objective: Reduced corruption through improved
transparency, integrity and accountability in business practices.
 Approach: Three levels: Individual companies, groups of companies
and business environment
Introduction
3

4. សន្ទសសន្៍នន្ការយល់ឃ ើញអំឃពើពុករលួយគឺ៖CPI 2015: THE BOTTOM 10
CPI 2016 for ASEAN
2
1. Corruption Perceptions Index (CPI) – ASEAN
Ranks more than 170 countries in terms of perceived levels of public
sector corruption, as determined by expert assessments and opinion surveys
84
49
37
35 35
33
30
28
21
Singapore Malaysia Indonesia Thailand Philippines Vietnam Laos Myanmar Cambodia
22
20
21 21 21
2012 2013 2014 2015 2016
Ranking:
156/176

5. Perception of corruption, by institution - proportion that think most or
all are corrupt – Cambodia
2. Global Corruption Barometer 2016 - Cambodia
5
6%
6%
24%
25%
25%
32%
41%
44%
52%
59%
Traditional leaders
Religious leaders
Local government councilors
Members of Parliament
Business executives
Tax officials
The Office of the President/ Prime Minister
Government officials
Police
Judges and Magistrates

6. 22% preferred not to talk about corruption or said that
they were not able to define corruption
47% said that they have heard of or experienced
corruption issues
57% think that corruption is one of the external factor
impeding their company’s progress
40% had to pay unofficial fees in connection with
inspections while 30% did not have to pay anything.
63% have never discussed business integrity in their
company
3. SME Research Findings
6

7.  Cambodia is an environment with a high
corruption risk
 Low trust in public institutions
 Low level of transparency combined with
complicated bureaucratic procedures
 Necessary to have a strong internal system to
prevent corruption (Corporate Integrity System)
Conclusion of Findings
7

8. What is a corporate integrity system
(CIS?)
 Essential component for ensuring business
integrity.
 Creates an internal governance structure that
limits the possibilities for nepotism, conflict of
interest, and corruption.
 Set of policies and procedures for a variety of
topics that may put your company at risk for
corruption.
4. Corporate Integrity Systems (CIS)

9.  Reduces costs to
business.
 Clear trainings for
staff, managers, and
directors.
 Clear policies and
procedures that staff
can consult.
 In line with
international
standards.
 Attractive to investors
Benefits of CIS

10. Key Areas of Concern
1. Gifts and
Hospitality
2. Facilitation
Payment
3. Conflict of
Interest
4. Charitable
Donations and
Sponsorship
5. Whistleblowing
6. Personal
Integrity Statement
or Anti-Corruption
Pledge
7. Integrity Pact

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CIS Process

12.  Make sure to check all relevant law for the country
you are operating. Ex. Anti-Corruption Law
 Consider your company or operating context. Ex. Are
you a small or large company? Is gift giving cultural?
 Define important terms so there are clear
explanations in the policies.
 Explain the policy clearly. Ex. No gifts will be given or
accepted worth more than 50 USD.
 Follow the policy with clear procedures. Ex. Proper
forms and documentation.
CIS Policies: How to draft a good policy

13. What is a charitable contribution?
 Sometimes companies want to
contribute to certain charity events,
as part of their CSR, by offering
financial donations or even staff
time.
 Charitable contributions are a great
way for a business to get involved
and give back to the community.
 However, it’s important that your
charitable contributions are not
seemed as a way for you to gain
undue influence over someone,
particularly a government official or
another decision maker.
CIS Policy Example:
Charitable Contributions and Sponsorships

14. Recommended Policy Definitions
 Charitable Donations: donations, financial or in kind,
given for the purpose of supporting a worthy and
needy cause, through a registered charity. These
include loans, gifts of property, services, sponsorship
of tables at events, advertising or promotional
activities endorsing a charitable organisation. The
release of employees during office hours from the
employer to the charity also constitutes a donation.
 Sponsorship: Financing part of a project or event,
carried out by another person or organisation, in
return for advertisement.
CIS Policy Example
Charitable Contributions and Sponsorships

15. Recommended Policy:
 Charitable donations and sponsorships made to
secure a business deal are prohibited.
 Charitable donations and sponsorships relating to
political parties, are prohibited no matter if they are
direct or indirect. (Unless your company has a
political contribution policy).
 All charitable donation and sponsorship payments
must be accompanied by receipts.
CIS Policy Example
Charitable Contributions and Sponsorships

16. Recommended Procedure:
 All individuals or organisations requesting for a
contribution must fill out the Charitable Donations and
Sponsorships Application Form and deliver it to the
Integrity Manager either via e-mail or in person
 On receiving the form, the Integrity Manager must conduct
background checks within a reasonable number of
working days of receiving the form, covering the following
aspects:
 Upon completion of the background checks, the Integrity
Manager will present the application to the respective
authority who will make a decision within a reasonable
number of working days of receiving the application:
 Donations or sponsorships up to US$10,000: Chief
Executive Officer
 Donations or sponsorships greater than US$10,000:
Board of Directors
CIS Policy Example
Charitable Contributions and Sponsorships

17. Recommended Procedure:
 If the application is rejected or approved, the Integrity Manager
must send a refusal or acceptance letter to the requestor within
a reasonable number of working days of the date of decision
was made.
 On delivery of payment, a receipt must be obtained, recorded
and archived.
 For donations or sponsorships greater than US$1,000, the
beneficiary must provide a report, including relevant
documents, materials, and pictures pertaining to the event or
use of funds to the Integrity Manager within three months of the
delivery of payment.
 The Integrity Manager will provide quarterly reports to the
Committee on Governance and Integrity on charitable
donations and sponsorships made in the period.
CIS Policy Example
Charitable Contributions and Sponsorships

19. Action Turnaround time Responsible party
Conduct background checks 5 days Integrity Manager
Approvals 5 days ≤ US$10,000: CEO
> US$10,000: BOD
Provision of funds for
donations/sponsorships
10 days Finance Department
Maintain record of donations/sponsorships
including receipts, event reports and
statement of accounts
On-going Finance Department
CIS Policy Example
Charitable Contributions and Sponsorships

20. Interested in CIS for your
company?
10
Contact TI Cambodia
Set up a meeting
Assessment
Implementation
Contact us:
Sophia Aspesi Areias
Programme Manager
sophiaaspesiareias@ticambo
dia.org
Ms. Chhay Pidor
Senior Project Officer
pidorchhay@ticambodia.org

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Thank you!