1. Executive Director, Transparency International UK
Corruption
IMLPO
February 28th 2013
Robert Barrington
Executive Director, Transparency International UK

2. Agenda Is corruption still a problem? Shining a light on grey areas
Best practice
Global corruption trends

3. Is corruption still a problem? Corruption Perceptions Index 2012

4. Corruption Perceptions Index

5. Corruption Perceptions Index

6. Global Corruption Barometer [Transparency International 2010]
Where are bribes paid?
Global Corruption Barometer [Transparency International 2010]

7. Shining a light on grey areas Four areas where adequate procedures are inadequate

8. Grey area 1: Governance ‘Tone from the Top’
What is good anti-corruption governance?
What it is not…what we can learn from the banking crisis
Low board priority
Lack of board responsibility
Unclear reporting lines
Poor response to whistleblowing
Perverse remuneration incentives
Skimping on resources

9. Grey area 2: Risk assessment
Foundation of a good procedure
Conducted at too high a level…
Failing to capture the real risks
Little buy-in for complex assessment
Not linking with existing procedures

10. Grey area 3: Due Diligence
Flows from governance and risk assessment
How far should it go?
Suppliers, agents, targets, partners
What have we learnt?
The highest risk area is agents
Know who they are
Know who you can trust
Don’t rely on contractual provisions – but don’t do without them
Liability can no longer be outsourced

11. Grey area 4: Facilitation payments
What are they?
Do they matter?
Can they realistically be stopped?
Is there an acceptable transition period?
Will they be driven underground?

12. What is best practice?

13. What is best practice?

14. How well are companies doing?

15. TRAC report Survey of 105 companies globally Publicly-available data
Scored in 3 categories
anti-corruption systems
organisational transparency
country-by-country reporting
Maximum 23 points

16. TRAC report

17. TRAC report – Financial Services

18. TRAC report – Financial Services

19. Global Corruption Trends

20. Corruption - not just bribery
Money laundering
Other corrupt behaviours…
Lobbying?
Political financing?
Facilitating abusive tax avoidance?
Mis-selling?
Exceeding society’s licence to operate?

21. Global trends Legal framework and enforcement
Rise of civil society – India, China, MENA
Social media – open data
Corporate transparency – Dodd-Frank, EU Directive
Tax – secrecy jurisdictions
Government action – G8, G20, OGP, UNCAC
Money laundering – systemic questions 21 21

22. Global trends
The moral relativism that traditionally infects multinationals in hot, corrupt countries is going out of style.
Jonathan Guthrie, Financial Times HSBC exits Panama 22 22