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Corruption in the Mining Sector: Preliminary Overview 415
be responsible for organizing anticorruption training for MOM staff,
advising MOM staff on ethical issues, receiving reports of corruption
from MOM staff or the public, and investigating those reports (in collaboration,
if appropriate, with the internal audit department). The
ethics officer also should be a senior-level appointment and have adequate
staff to support him or her in carrying out the ethics function.
The ethics officer and relevant support staff should receive specific
anticorruption training that highlights the areas of corruption risk they
should be looking for. In addition, the ethics officer should be independent
and should report corruption on the same basis as described above
in relation to the internal audit function. Ethics officers should also be
appointed on the same basis as described above at all regional and city
licensing authorities.
Recommendation 5: Improve the appeals and complaints procedures.
Appeals and complaints procedures need to be in place at each licensing
authority for mining companies that are unhappy with any aspect of the
licensing and operations procedures of the licensing authorities and for
local inhabitants who believe they have been undercompensated. At the
federal level, complaints can be made to MOM’s ethics officer or by
completing a complaints form. However, the perception of some mining
companies interviewed was that these mechanisms may not always be
effective.
Recommendation 6: Encourage reporting of corruption.
Staff of the federal, regional, and city licensing authorities; staff of mining
companies; and members of the public should be strongly encouraged
to report any suspicions of corruption. Reporting can be to the
appropriate ethics officer or to whichever is appropriate of the FEACC,
the regional ethics and anticorruption commission, or the police.
People need to be assured that they may report anonymously if they
wish and that staff will suffer no prejudice in their employment if they
do report (unless the report is made maliciously). Reporting could be
encouraged by a publicity campaign on television and in the press.
A system for anonymous reporting could be established by providing
an address to which people can write with their complaints and by
informing people that they do not need to include their name and
address on the letter.