SLIDE 1
Looking Beyond Debarment
- Deterrence vs. Prevention
- Overall business climate
- Relative size and risk profile of
business
- Willingness to reform, but lack
- f capacity
- Bank mandate
2
Enhancing Business Integrity within the Private Sector Chiawen Kiew - - PowerPoint PPT Presentation
Enhancing Business Integrity within the Private Sector Chiawen Kiew - - PowerPoint PPT Presentation
Enhancing Business Integrity within the Private Sector Chiawen Kiew Office of the Chief Compliance Officer 24 May 2017 Looking Beyond Debarment Deterrence vs. Prevention Overall business climate Relative size and risk profile of
SLIDE 2
SLIDE 3
- Corruption in connection with procurement at Latvian Power Plant by the
largest engineering firm in Turkey.
- Sanctions imposed
- Debarment of subsidiary
- Compliance enhancements at holding company
- Engagement of monitor for a period of 3 years.
Procurement Case Study - Background
3
SLIDE 4
- Compliance enhancements to date
- Creation of compliance organization
- Implementation of third-party due diligence procedure
- Adoption of Code of Business Conduct
- Business integrity training of all employees (ongoing)
- Launch of anonymous reporting hotline
- Enhanced payment controls around gifts, hospitality, donations, and
sponsorships
- Benefits of the approach
- Reduced risk of recidivism
- 400 projects in 25 countries, many “high risk”
- Almost 10,000 employees
- Catalyst for regional business integrity improvement
Procurement Case Study - Status
4
SLIDE 5
Focus Country – Ukraine
5
- Four corruption-related enforcement actions 2015-2016
#
Subject
Payments Benefit Result 1 ACTI Ukraine (Subsidiary of multinational agribusiness corporation) US$22 million US$100 million in VAT refunds 3-year debarment 2 Medium-sized, family-
- wned plastic manufacturer
€7.2 million VAT refunds, customs clearance, court case facilitation 3-year conditional nondebarment 3 Medium-sized, family-
- wned steel manufacturer
€4.3 million €18.3 million in VAT refunds 3-year conditional nondebarment 4 Medium-sized, regional grain trading company US$380,000 Land registration 3-year conditional nondebarment
SLIDE 6
- Improved “Specific” and
“General” Prevention
- Establishment of anti-corruption
function
- Establishment of audit function
- Training of board and senior
management
- Increased awareness of
business integrity
Focus Country – Ukraine (cont’d)
6
SLIDE 7
- Enhance legislation
- Tighten requirements on corporate governance and business integrity
- Establish proper corporate liability
- Establish defence based on adequate internal controls (i.e., UK Bribery
Act)
- Raise awareness of business integrity issues
- Co-operation with Chambers of Commerce
- Awareness-raising events
- Increase enforcement related to business integrity issues
What Can Government Do?
7
SLIDE 8
Questions?
8