Freeman Cebu Business

Did you celebrate the ‘International Anti-Corruption Day’ on December 9?

INTEGRITY BEAT - Henry J. Schumacher - The Freeman

The International Anti-Corruption Day was on December 9. I am glad that GAN Integrity reminded me of that important day. GAN Integrity added that anti-corruption activists, regulators, and compliance professionals around the world reminded us that there is no country, organization, or individual that is exempt from the detrimental effects of corruption. 

This year, despite the global pandemic, important advancements and enforcement decisions occurred that lead us towards a more transparent world. As companies in the EU prepare for a groundbreaking new directive on whistleblowing, U.S. authorities updated their guidelines on the enforcement of the FCPA, and the U.S. Securities and Exchange Commission’s (SEC) whistleblower program set new records by handing out the highest sum in whistleblower awards in its history. In the Philippines, whistleblower protection still needs to be improved if the anti-corruption endeavors are to be successful.

To commemorate the Anti-Corruption Day, let’s look at some compliance essentials:

Anti-Corruption Training

Training employees on anti-corruption is necessary for protecting organizations from risk and ensuring that employees are acting in a way that is reflective of the ethical standards set by the company.Training may take many forms, including e-learning courses, traditional on-site training, internal communications, and electronic and physical policy signings.

Topics can include anti-corruption practices within organizations as well as anti-corruption best practices when managing third party relationships such as vendors and sales agents. Please be reminded that there is still plenty of company-to-company corruption going on which the Integrity Initiative is presently trying to address.

Bid Rigging

Bid rigging is a form of collusion in which bidders on a contract decide who should be successful in the tender, and then draft their bids accordingly. Bid rigging is a form of market manipulation and can have significant antitrust implications (the Philippine Competition Commission is watching these activities closely).

Business Ethics

Business ethics are the values a company upholds throughout its operations. Common ethical considerations include human rights, the environment, anti-corruption, and labor rights. Within each of these overarching areas, organizations typically make commitments to specific ethical standards and moral practices based on the industry they operate in and the corporate culture the company wants to promote. 

Code of Conduct

A code of conduct is the most common policy within an organization. This policy lays out the company’s principles, standards, and the moral and ethical expectations that employees and third parties are held to as they interact with the organization. A code of conduct is an integral part of compliance efforts as it provides documentation that an employee or third party has violated company policy if illegal activity arises. Do you have one? Is it known to all employees and business partners?

Corporate Liability

Corporate liability is the legal responsibility a corporation assumes for acts committed by the organization’s employees or agents acting on its behalf. In the eyes of the law, corporations are seen as “persons” or individuals who can be prosecuted and liable for actions. Distinctly separating corporations this way gives them the ability to own assets and take on liability separate from the owners or leaders of the company. Corporate liability determines the extent to which the organization is liable for the actions of its employees. 


Fraud involves the use of deception, trickery, and a breach of trust to gain an unfair or unlawful advantage. Occupational fraud entails the use of one’s occupation for personal enrichment through the deliberate misuse or misapplication of a company’s resources or assets.

Money Laundering

Money laundering defined as the method in which illegally obtained money is altered to make the translation look legitimate. What constitutes money laundering? Money laundering occurs when the location, source, ownership, or control of funds are falsified. 

Money laundering is illegal because it is a way for criminals to profit from crime and often involve more than one illegal activity. Both the act and origin of money laundering make it illegal. The first crime occurs when a criminal secures the funds and the second crime is trying to legitimize the proceeds by misusing financial institutions.

It was good to see in yesterday’s papers, that Senator Grace Poe, the Head of the Senate Committee on Banks and Financial Intermediaries, endorsed for plenary action the urgently needed amendments to the AMLA Act.

GAN Integrity and the Integrity Initiative are strong believers that technology will continue to play a key role in shaping the global fight against corruption. If you need additional information or assistance to improve compliance, contact GAN Integrity directly or contact me at [email protected]

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