Business Against Corruption - A Framework for Action - International ...

BusinessagainstcOrruptiona frameworkfor action

About the United Nations Global CompactLaunched in 2000, the United Nations Global Compact is a both a policyplatform and a practical framework for companies that are committed tosustainability and responsible business practices. As a multi-stakeholderleadership initiative, it seeks to align business operations and strategieswith ten universally accepted principles in the areas of human rights, labour,environment and anti-corruption and to catalyze actions in support ofbroader UN goals. It is the world’s largest voluntary corporate citizenshipinitiative, with over 6,500 signatories based in more than 130 countries.For more information, please visit www.unglobalcompact.org.Contributors to Update (2011) in alphabetical order : Peter Brew,Da Woon Chung, Susan Cote-Freeman, Brook Horowitz, Olajobi Makinwa,Adam Trott, and Peter WilkinsonDesigner: Megan LarsonCopyright © 2011United Nations Global Compact OfficeTwo United Nations Plaza, New York, NY 10017, USAEmail: globalcompact@un.orgDisclaimerThe inclusion of company examples in this publication is intended strictlyfor learning purposes and does not constitute an endorsement of the individualcompanies by the United Nations Global Compact Office.The material inthis publication may be quoted and used provided there is proper attribution.

1ContentsForeword 2Introduction: The Pressure Continues to Build 3The Case for Fighting Corruption 5Understanding the 10th Principle 8Practical Steps to Fight Corruption:The Management Model 9Collective Action 15Tools and Resources 20

2 Business Against CorruptionForewordIn the six years since the initial 2005 publication of Business Against Corruption: A Framework ForAction, corruption has remained one of the world’s greatest challenges. Now as then, it is a majorhindrance to sustainable development, with a disproportionate impact on poor communities,and it is corrosive to the very fabric of society. Its impact on the private sector is considerableand costly: It impedes economic growth, distorts competition and represents serious legal andreputational risks.While the threat of corruption has not declined in significance since 2005, the world is betterequipped to fight it than ever before. So far, 140 countries have become signatories to theUnited Nations Convention against Corruption, an international anti-corruption instrumentadopted by the United Nations General Assembly in 2003 and entered into force in 2005.Further, the number, scope and severity of national laws intended to fight corruption worldwidehave increased substantially, with initial, promising results visible in all regions of the globe.Overall, governments are increasingly proactive in enforcing their anti-corruption laws, oftenwith international effect. Finally, a simple Internet search reveals a multitude of tools andinitiatives—many of which did not exist in 2005, or have grown much since—that, together,can assist companies in this endeavour. Despite such noteworthy efforts, business participantsof the UN Global Compact consistently indicate that the 10th Principle against Corruption is themost difficult principle to implement, and call for more clarity and guidance on existing toolsand resources that would assist companies in implementing anti-corruption measures.While the core principles and challenges remain unchanged, this document has been revisedto reflect the developments of the past six years. Most significantly, the introduction tracesrecent developments in the field. This document now incorporates both the UN Global CompactManagement Model (2010) and the Global Compact-Transparency International Reporting Guidance onthe 10th Principle against Corruption (2009) as well as other new tools and active initiatives.Business Against Corruption is a guide to companies preparing themselves to implement theUN Global Compact’s 10th Principle against Corruption and to deal with corruption in anyand every aspect of their operations. It provides a road map and tools that will assist in thepractical application of policies designed to eliminate corruption. We hope that all who readthis document, especially participants of the Global Compact, will use this framework foraction to help eliminate the threat of corruption within their respective business structures.More important, we hope that, six years from now, business (as well as government) will haveeffectively advanced the anti-corruption agenda, and that we will be able to report a declinein corruption’s significance as a threat to sustainable development.Georg KellExecutive DirectorU.N. Global CompactHuguette LabelleChairTransparency InternationalClare MelfordChief Executive OfficerInternational Business Leaders

3Introduction: The pressure continues to buildThere are many reasons why the eliminationof corruption has become a priority withinthe business community. Confidence andtrust in business among investors, customers,employees and the public have been erodedby recent waves of business ethics scandalsaround the globe. Several high-profile casesof bribery are currently being investigated orprosecuted. Companies are learning the hardway that they can be held responsible for notpaying enough attention to the actions oftheir employees, associated companies, businesspartners and agents.The rapid development of rules of corporategovernance around the world is alsoprompting companies to focus on anti-corruptionmeasures as part of their mechanisms toexpress corporate responsibility and to protecttheir reputations and the interests of theirstakeholders. Their anti-corruption systemsare increasingly being extended to a rangeof ethics and integrity issues, and a growingnumber of investment managers are lookingto these systems as evidence that the companiesundertake good business practice and arewell-managed.The decades-long underestimation of thesocial and economic costs of corruption isbeing replaced by an understanding across allsectors of its devastating impact on our society.Virtually all countries have now criminalizedbribery within their domestic arenas,and, recognizing that corruption is not justa local or a national problem but to a largeextent a regional and international problem,various international organizations have developedinstruments to fight corruption at theglobal level. In most countries where corruptionis rife, there are also local organizationsand pressure groups working to combat it.The international fight against corruptionstarted to gain momentum through the 1997Organisation for Economic Co-operation andDevelopment (OECD) Convention on CombatingBribery of Foreign Public Officials in InternationalBusiness Transactions, and throughthe adoption of the first globally agreed-uponinstrument, the United Nations Conventionagainst Corruption (UNCAC) in 2003 and itssubsequent entry into force in December 2005.The introduction of the UN Global Compact’s10th Principle against Corruption in 2004 was afurther significant step in bringing anti-corruptioninto the corporate responsibility agenda.National efforts to bolster transparencyand anti-corruption enforcement have followedsuit, with international effect. As of2010, all mining, oil and gas firms listed onthe New York Stock Exchange are legallyobligated to disclose payments made togovernments for access to natural resources.The Hong Kong Stock Exchange has alreadyintroduced similar rules for newly listed companies,and, as of March 2011, the EuropeanCommission is expected to pass a similarlaw. Laws and ministries requiring increasedtransparency as a corruption-fighting devicehave recently arisen around the world,from Bangladesh and Bolivia to Jordan andSenegal. Laws criminalizing corruption havebeen strengthened in places such as China,India, Russia and Uganda, while Brazil’sFicha Limpa law bars anyone convicted ofserious crimes, including corruption charges,from running for political office. The UnitedStates has increased the enforcement of itsanti-corruption laws and the correspondingpenalties, and in eastern Africa the KenyanAnti-Corruption Commission is continuing tomake progress 1 .Activity in this area goes beyond organizationscomprising government ministers: Agrowing number of international organizationsare not only recognizing the role ofbusiness in proactively fighting corruptionas crucial for success, but are also expectingbusinesses to do something about it. TheGroup of 20 (G20) has recognized business asa stakeholder in anti-corruption efforts andconsiders its engagement essential. The UNGlobal Compact, the International Chamberof Commerce, Transparency International,and the World Economic Forum—PartneringAgainst Corruption Initiative (PACI) led asix-month campaign concluding with a statementsigned by leading CEOs from around theworld, which led to the adoption of a resolutionby the Conference of States Parties explicitlyreferring to the role of the private sectorin monitoring and reviewing the UNCAC.The world’s multilateral developmentbanks (MDBs)—including the World Bank,1See, e.g., The Fight Against Corruption: Naming and Shaming. (2010, October 28). The Economist.

4 Business Against Corruptionthe African Development Bank, the AsianDevelopment Bank, the European Bank forReconstruction and Development, and theInter-American Development Bank Group—agreed in 2010 that if one MDB declares afirm or an individual ineligible for procurementcontracts because of fraud and corruption,then all the other MDBs will do thesame. In 2010 alone, the World Bank banneddozens of contractors guilty of corruptionfrom bidding on projects supported by WorldBank funds and launched its InternationalCorruption Hunters Alliance, which supportscorruption fighters internationally. A coalitionof investors, with funds totalling US $1.7trillion, requested in 2010 that companiesacross eight sectors and 14 countries improvetheir disclosure of corruption risks andresponses. Non-governmental organizationsfrom the global Transparency Internationalmovement to the Mombasa-based Muhari arebecoming ever more vigilant as more informationbecomes public, and the growth ofsuch initiatives has only begun.Companies are key participants in the fightagainst corruption and are expected to step upmore than ever before. Pressure is starting tobuild from within as much as from without.As detailed on the following pages, companiesshould proactively express their commitmentto corporate responsibility and voluntarilyfight corruption for reasons unrelatedto the potential legal ramifications of beingcaught in the act. The UN Global Compactserves as a learning and performance platformto assist companies in this endeavour. Only byfully implementing solid institutional policies,reporting on their implementation and engagingin collective action can companies be sufficientlyassured that the tinge of corruptionwill not apply to them. Only then can globallysustainable business truly succeed.

5The case for fighting corruptionBusinesses face high (and related) ethical andbusiness risks and potential costs when theyfail to effectively combat corruption in all itsforms. As part of the problem, they can alsobe part of the solution. This section addresseswhy all companies should have zero toleranceof corruption.The ethical caseCorruption is inherently wrong. It is a misuseof power and position and has a disproportionateimpact on the poor and disadvantaged.It undermines the integrity of all involvedand damages the fabric of the organizationsto which they belong, potentially decreasingmorale (and therefore productivity).The reality that laws criminalizing corruptpractices may not always be enforced—thoughenforcement is increasing—is no justificationfor accepting (or perpetuating) corrupt practices.To fight corruption in all its forms is simplythe right thing to do, whether or not peopleoutside an organization ever see the results.The business caseCompanies need not justify their efforts tofight corruption on an ethical basis alone.It is also in a company’s business interestto ensure that it does not engage in corruptpractices. All companies, large and small, arevulnerable to corruption, and the potentialfor internal damage is considerable. The followingare some key reasons for avoiding involvementin corrupt practices and for takingan active role in combating it and its effects.■■Legal risksRegardless of what form a corrupt transactionmay take, there are obvious legalrisks involved. Not only are most forms ofcorruption illegal where they occur, butit is also increasingly becoming illegal ina company’s home country to engage incorrupt practices in another country. Theprinciple that it is illegal to bribe foreignofficials was first established in the USForeign Corrupt Practices Act of 1977.Since then, this principle has gained legalstanding within the whole of the OECDand in a number of other countries. It wasuniversally recognized in 2003, throughthe adoption of the UNCAC.The enforcement of anti-corruptionlegislation internationally has so far beenrelatively weak, but this is slowly changing.According to Shearman and Sterling, aninternational law firm based in New York,2009 and 2010 were record years in termsof the number of prosecutions broughtagainst corporations by the United States.In 2010 alone, over US $1.75 trillion inpenalties was assessed (another record),about 80 per cent of which was assessedagainst non-US-based corporations. The USgovernment has continued to hold individualsaccountable, with 13 people sentencedto prison time or probation. The UnitedKingdom’s Bribery Act 2010, which willcome into force on July 1, 2011, will alsohave substantial international effect.In developing countries and emergingmarkets, where the opportunity forcorruption has been rife because of weaklaws, regulations and enforcement mechanisms,corruption has become an issue ofsignificant political importance, and thereis a growing determination to act and totake those accused of corrupt practicesto court. As noted on the previous pages,there has been a flurry of legislationaround the world intended to create, orto extend the reach and enforcement of,anti-corruption laws.There are also a growing number of examplesin which developing countries withlimited capacity to handle such cases haveobtained outside legal assistance. To thisend, the OECD is playing a critical role inensuring that its member states are developinga judiciary capable of enforcing theprohibition against the bribery of foreignofficials, and, more broadly, the UN Officeon Drugs and Crime (UNODC) is proactivelypromoting the adoption and implementationof the UNCAC through various meansof technical assistance to governments.The UNODC is also developing a web-basedcollaborative forum that will serve as arepository of anti-corruption-related knowledgeand has, with the World Bank Group,implemented the Stolen Asset Recovery(StAR) Initiative, which lowers the barriersto the recovery of assets stolen throughacts of corruption. The UNODC is active instrengthening the integrity of the judiciarywhere it has been ethically compromised,developing outreach activities, workingwith the private sector, and following up

6 Business Against Corruptionwith many other actions that increase thecapacity of countries to implement theirown anti-corruption laws.This changing environment of law,regulation and enforcement makes it moredifficult for boards and business managersto assess and quantify the legal risks towhich corruption exposes their operations.Change brings uncertainty. Of particularsignificance for many large companiesis the degree to which they may be heldresponsible for agents and other intermediariesacting on their behalf in othercountries. What may yesterday have beenconsidered an independent agent—forwhom the principal company carried noresponsibility—may, today or tomorrow, besomeone for whose actions the principalcompany may be held legally accountable.The United Kingdom’s Bribery Act 2010, forexample, creates liability for corporationswhen a person “associated” with the corporation(including third-party associates)bribes another person to obtain business ora business advantage for the corporation.The only defence is that the company had“adequate measures” in place to preventbribery. Furthermore, the Act expresslyprovides for board and senior executive liabilityin certain circumstances.As mentioned in Clean Business is GoodBusiness, a joint publication of the UNGlobal Compact, TI, the ICC and the WorldEconomic Forum—PACI, an increasingnumber of companies are implementing effectiveanti-corruption programmes, whichinclude detailed policies on company-specificbribery issues and strong managementsystems. But they are still a minority.■■Reputational risksBased on the experience of recent years,companies whose policies and practices failto meet high ethical standards, or that takea relaxed attitude toward compliance withlaws, are exposed to serious reputationalrisks. Often it is enough to be accused ofmalpractice for a company’s reputation tobe damaged, even if a court subsequentlydetermines that the company has not beeninvolved in corrupt practices. It is of criticalimportance for a company to be able toquickly quash any unfounded allegationsby demonstrating that it acts transparentlyand has in place policies and proceduresdesigned to prevent corrupt acts. Theargument that a company’s actions wereconsistent with the way business was donein a particular country, even though thoseactions are illegal, is not an acceptable excuse.Nor is it sufficient to claim that othercompanies and competitors have engagedin similar practices.■■Financial costsAccording to the World Bank, over US $1trillion is paid in bribes each year aroundthe world. There is clear evidence that inmany countries corruption adds up to 10per cent to the cost of doing business andthat corruption adds as much as 25 percent to the cost of public procurement.This undermines business performance anddiverts public resources from legitimatesustainable development while leading topotentially lower-quality results.■ ■ “Known as clean”and repeat demandsThere is growing evidence that a companyis less likely to be under pressure to paybribes if it has not done so in the past. Oncea bribe is paid, repeat demands are possibleand the amounts demanded are likely torise. Conversely, a company that takes afirm and principled stand against all formsof corruption will become known for this,and the risk of its employees’ being exposedto demands will decrease.■■Blackmail, no recourseand security risksBy engaging in corrupt practices, companymanagers expose themselves to blackmail.Consequently, the security of staff, plantand other assets is put at risk. Companiesface “casino risk”—i.e., a lack of legal remedies—ifa counterpart does not deliver asagreed where corruption was involved.■ ■ Erosion of internal trustand confidenceIf a company engages in or toleratescorrupt practice, it will soon be widelyknown internally and externally. Unethicalbehaviour erodes staff loyalty to thecompany, and it can be difficult for staffto see why high standards should be appliedwithin a company when they do notapply in the company’s external relations.It may also become more challenging tohire and keep talent.

7■■Companies have a vested interest insustainable social, economic andenvironmental developmentIt is now clear that corruption has playeda major part in undermining the world’ssocial, economic and environmental development.Resources have been diverted toimproper use, and the quality of servicesand materials used for development hasbeen seriously compromised. The impact onpoorer communities struggling to improvetheir lives has been devastating and inmany cases undermines the very fabric ofsociety. Corruption has also led to environmentalmismanagement, underminedlabour standards and restricted access tobasic human rights.Business has a vested interest in socialstability and in the positive economicgrowth of local communities. It has thereforesuffered, albeit indirectly, from theimpact of lost opportunities to extendmarkets and supply chains. The businesscommunity can and should play its part inmaking corruption unacceptable.It is important to recognize that corruptiondiverts resources from proper use.Financial resources that were intended forlocal development may, as a result of corruption,end up in foreign bank accountsinstead of being used for local purchasingand the stimulation of local economies. Atthe same time, corruption distorts competitionand creates gross inefficienciesin the public and private sectors. In mostcases where corruption occurs, the servicesor products being purchased are inferiorto what had been expected or contractedfor. In some cases, corruption has led tothe loss of lives. Its effects have been seenwhen buildings collapse because of shoddyworkmanship. According to a January 2011study reviewing the past 30 years of deathscaused by the collapse of buildings inearthquakes, 83 per cent of several hundredthousand total deaths have occurred in“anomalously corrupt” countries 2 . The longtermsustainability of business depends onfree and fair competition.Corrupt practices also accompany andfacilitate drug-dealing and organizedcrime. Money-laundering and illicit internationalmoney transfers are used as supportmechanisms for international terrorism.Global businesses must be constantlyvigilant to avoid being associated withthese major international challenges. Asshown on the following pages, companiesthat engage in the fight against corruptionindividually and collectively will stand togain benefits to their businesses, directlyand indirectly.2Ambraseys, N., & Bilham, R. (2011, January 13). Corruption Kills. Nature, 469, 153-55. doi:10.1038/469153a

8 Business Against CorruptionUnderstanding the 10th PrincipleThe UN Global Compact’s10th PrincipleFollowing the United Nations General Assembly’s2003 adoption of the United Nations Conventionagainst Corruption (UNCAC), the UN GlobalCompact added its 10th Principle in 2004:“Businesses should work againstcorruption in all its forms, includingextortion and bribery.”Objectives of the 10th PrincipleThe adoption of the 10th Principle commitsUN Global Compact participants not only toavoid bribery, extortion and other forms ofcorruption, but also to proactively developpolicies and concrete programmes to addresscorruption internally and within their supplychains. Companies are challenged to join civilsociety, the United Nations and governmentsto realize a more transparent global economy.With the entry into force of the UNCACin 2005, an important global tool to fightcorruption became law. The UNCAC is theunderlying legal instrument that inspired the10th Principle.■■How is corruption defined?Corruption is defined by Transparency Internationalas “the abuse of entrusted powerfor private gain.” This convenient shorthand,encompassing myriad illegal and illicitacts, recognizes the breadth of the conceptbut does not attempt to enumerate orprecisely delimit. During the negotiations ofthe UNCAC, United Nations Member Statescarefully considered the opportunity forthe global anti-corruption treaty to providea legal definition of corruption. Concludingthat any attempt at a comprehensivedefinition inevitably would fail to addresssome relevant forms of corrupt behaviour,the international community reached globalconsensus on a large number of manifestationsof corruption while leaving each Statefree to go beyond the minimum standardsset forth in the Convention.The Convention calls for ratifying Statesto outlaw, at a minimum, bribery of publicofficials; embezzlement, trading in influence,abuse of function, and illicit enrichmentby public officials; and bribery andembezzlement in the private sector, as wellas money-laundering and obstruction ofjustice. These corrupt actions are spelled outunder the chapter of the Convention devotedto criminalization and law enforcement,denoting that corruption—which is a notionwider than bribery and extortion—is a crime.In consonance with this approach, the UNGlobal Compact’s 10th Principle calls forcompanies to work against corruption in allits forms, including extortion and bribery.■■What is extortion?The OECD Guidelines for Multinational Enterprisesdefines extortion: “The solicitationof bribes is the act of asking or enticing anotherto commit bribery. It becomes extortionwhen the demand is accompanied bythreats that endanger the personal integrityor the life of the private actors involved.”■■And what is bribery?The UNCAC Articles 15 and 21 definebribery of public officials and in the privatesector, respectively:(a) The promise, offering or giving, to apublic official, directly or indirectly,of an undue advantage, for the officialhimself or herself or another personor entity [or any person who directs orworks, in any capacity, for a privatesector entity], in order that the official[or person] act or refrain from acting inthe exercise of his or her official duties[or that he or she, in breach of his orher duties, act or refrain from acting](b) The solicitation or acceptance by a publicofficial [or by any person who directsor works, in any capacity, for a privatesector entity], directly or indirectly, of anundue advantage, for the official himselfor herself or another person or entity, inorder that the official act or refrain fromacting in the exercise of his or her officialduties [or that he or she, in breach of hisor her duties, act or refrain from acting]The Business Principles for Countering Briberyinitiated by TI defines the term “bribery”:“An offer or receipt of any gift, loan, fee,reward or other advantage to or from any personas an inducement to do something whichis dishonest, illegal or a breach of trust, in theconduct of the enterprise’s business.”

9Practical steps to fight corruption: The Management ModelThe UN Global Compact suggests to itsparticipants that they consider using the UNGlobal Compact Management Model 3 infighting corruption and implementing the10th Principle, as well as for each of the otherthree Global Compact issue areas. Publishedin partnership with Deloitte, an internationalaccounting and consulting firm, it guidescompanies through the process of formallycommitting to, assessing, defining, implementing,measuring and communicating acorporate sustainability strategy based on theGlobal Compact and its Ten Principles.Companies are encouraged to constantlyrefine their management processes and proceduresand to view their actions as a cycle ofcontinual improvement, in addition to settingtheir sights on an end goal of eliminatingcorruption. The Management Model embodiesthis idea in its presentation as an unbrokencircle, rather than as a more linear path. Inother words, companies should, yearly ormore regularly, re-commit themselves to theprocess and follow each of the steps: Circumstancesmay change and company leadershipmay change, but the commitment to fightingcorruption should never flag.Details on each of the six steps as appliedto anti-corruption measures are found on thefollowing pages. The following section coverscollective action, in which companies joinforces with industry peers and other stakeholdersas part of the fight against corruption.For more informationon the ManagementModel, pleasevisit the UN GlobalCompact website.UN Global Compact Office and Deloitte, UN Global Compact Management Model (2010)

10 Business Against CorruptionCommitAs with most management challenges acompany faces, clear leadership is essential ifa company is to ensure that it and its agentsare not engaging in corrupt practices. It isimportant that the top management not sendmixed signals: on the one hand to urge companymanagers and representatives to applystringent codes and high standards, while onthe other to make it clear that these codes areopen for interpretation, often with referenceto the importance of adapting business practicesto the local environment.Thus, the first step any company shouldtake in fighting corruption is to have leadershipcommitments to zero tolerance ofbribery and to mainstream anti-corruptionpolicies into its everyday operations, doingso in a transparent way. Companies shouldensure that oversight of anti-corruption measuresis provided by transparent governancestructures within the company.AssessWith a firm commitment to fighting corruptionin hand, companies should assessthe risks and opportunities—in financialand extra-financial terms—found in enforcingstrict anti-corruption measures, as wellas the impact of their operations on thefight against corruption and vice versa. Byunderstanding the context and risks underwhich they operate, companies can gaina more comprehensive view of the scopeof the problem and the areas of greatestconcern and importance, and thus set highbut realistic goals achievable over a certaintime period. Companies should continuallyre-assess as circumstances change and aspolicies and procedures are shown to be successes(or failures).As a company identifies its risks, it mayfind areas of operation that, if improved, cancreate shareholder and stakeholder value.When dealing with corruption, this may bereadily apparent: Through its elimination notonly does a company avoid legal, reputationaland other risks, but the company also retainsmorale and capital, increasing the potentialfor efficient production.Finally, by assessing the impact of itsoperations and the impact of corruption onits operations, a company will be able to answerquestions posed by stakeholders and tocalculate the areas of high risk that should beaddressed first. Companies are encouraged tolook at the Communication on Progress andother sustainability reports of competitors tohelp determine the best ways to benchmarktheir own performance.DefineOnce a company has a comprehensiveunderstanding of its context, it should sethigh but realistic goals to adhere to the 10thPrinciple against Corruption, address its risksand pursue opportunities. As part of this step,companies should determine which indicatorsthey will use to measure their progressand to determine whether a particular policyor programme is successful.Once a company has defined its goals, itshould construct and adopt strategies andpolicies to achieve them. Such policies mayinclude an ethics code aimed at capturing thevalues that underpin an organization, andthey should be applied to all relevant businesspractices.Voluntary compliance with internal codesof business principles and ethics, and withexternal guidelines such as the BusinessPrinciples for Countering Bribery, which weredeveloped by a multi-stakeholder approachled by Transparency International, and the UNGlobal Compact’s 10th Principle, has the addedeffect of strengthening day-to-day compliancewith law and regulation. When companiesset and reinforce high standards of behaviouras the norm, incidents of non-compliance arereduced and are easier to identify and correct.Codes and advice on ethics programmescan be obtained from organizations such asthe Ethics Resource Centre. Guidance on theintroduction of anti-bribery programmes isprovided by TI and the International Chamberof Commerce (ICC).In addition to such broad principles, thereare an increasing number of specific initiativesaimed at addressing some of the challengesthat may be encountered in particularsectors. The World Economic Forum—PACI,which began as a sector-specific project forthe engineering and construction industry, isa pragmatic step toward broader implementationof anti-corruption measures.ImplementPrinciples and codes are rarely sufficient inthemselves; they have to be accompaniedby training and follow-up, ensuring that anethical culture is developed within a companythrough a consistent strategy. Continu-

15Collective actionOften a local business leader takes the viewthat, although it would be desirable toexclude all forms of corruption, he or shecannot do it alone. There is at times a perceptionthat corruption—from petty bribery andso-called facilitation payments to large-scalecorrupt acts—is so much part of local culturethat there is no remedy for the individualcompany. Although business managers mayrecognize that corruption is a problem, theymay not consider it their role to change thebusiness culture.In these circumstances, collective actionwith other companies provides one of thekey solutions. “Collective Action” is a processof cooperation between various stakeholderswith the aim to jointly counter corruption.Through such alliance of like-minded organizationsthe problem can be approached andresolved from multiple angles, and the impactof individual action can be increased. Theultimate aim of these joint efforts is to createfair and equal market conditions—a “levelplaying field”—for all market players and toeliminate the temptations of corruption forall of them. 5Collective Action can be initiated anddriven through various channels. The availablemethods range from Integrity Pactsfor individual procurement transactionsto industry-specific codes of conduct andcompliance pacts, as well as joint measuresimplemented as part of a long-term initiativeto raise a country’s public awareness andtighten up its regulatory system and procurementguidelines. 6Integrity Pactshttp://www.transparency.org/global_priorities/public_contracting/integrity_pactsDeveloped by Transparency International, theIntegrity Pact (IP) is a tool aimed at preventingcorruption in public procurement. Theprocess starts with an agreement between agovernment institution and all bidders for apublic sector contract. An IP calls for independentoversight of this agreement. It containsthe rights and obligations of all parties to thecontract, to the effect that neither the governmentprocurer nor any of the bidders willpay, offer, demand or accept bribes, or colludewith competitors to obtain the contract, orengage in such abuses while carrying it out.Furthermore, bidders will disclose all commissionsand similar expenses paid by themto anybody in connection with the contract,and sanctions will apply when violations occur.These sanctions range from loss or denialof contract, forfeiture of the bid or performancebond, and liability for damages, tobidders’ being blacklisted for future contractsand government employees’ being subjectedto criminal or disciplinary action.The IP provides companies with a levelplaying field where all competitors are boundby the same rules, thereby discouraging theuse of bribes. It allows governments to reducethe high cost of corruption in procurement,privatization and licensing. The IP has shownitself to be adaptable to many legal settingsand to be flexible in its application.Compliance pacts or codesof conduct 7Compliance pacts are industry- or sectorspecificcontractual agreements betweencompanies. A group of companies operatingin the same industry launches an initiativewith defined compliance principles orrequirements to which its members mustadhere. The pacts are particularly suitable foruse in high-risk industries and oligopolisticmarkets; their success depends on extensivemarket coverage. Signing organizations agreeto such codes of ethical conduct, which comprisebusiness principles that reject briberyand corruption, and which may be based onexisting principles, such as the Principles forCountering Bribery of the World EconomicForum—PACI. Signing the PACI Principles car-5Adopted directly from Collective Action in the Fight Against Corruption (2010) http://www.unglobalcompact.org/docs/issues_doc/Anti-Corruption/CollectiveAction2010.pdf- A joint publication by the members of the World Bank Institute Working Group (the World Bank Institute, the Centerfor International Private Enterprise, Global Advice Network, Grant Thornton, Siemens, Transparency International and the United NationsGlobal Compact)6Adopted directly from Collective Action in the Fight Against Corruption (2010) http://www.unglobalcompact.org/docs/issues_doc/Anti-Corruption/CollectiveAction2010.pdf.7http://www.weforum.org/pdf/paci/PACI_Principles.pdf and http://www.transparency.org/global_priorities/private_sector/

16 Business Against Corruptionries no legal obligations, but signatories willbe held accountable by the general public andthe media. 8 In order to avoid any anti-trustissues, a neutral mediator (e.g., an industryassociation, a chamber of commerce or a nongovernmentalorganization) must be involvedin the preparation of the compliance pact.Long-term initiativesAn important tool in the fight againstcorruption is the cooperation between acountry’s key stakeholder groups, includingmembers of the public sector, the private sectorand civil society, with the aim to createa deep-rooted anti-corruption culture in aparticular country or sector. Such long-terminitiatives create the fundamental conditionsrequired for project-specific Integrity Pactsand industry-specific Compliance pacts tobe effective in the long run. Such initiativesmay include the promotion of CollectiveAction methods by companies, the organizationof business round tables, best practicesharing, information campaigns and anticorruptiontraining by local chambers of industryand commerce or NGOs, and cooperationwith local anti-corruption authorities onregulatory reform 9 .Tools and organizations thatsupport collective actionFighting Corruption through CollectiveAction – A Guide for Businesshttp://www.unglobalcompact.org/docs/news_events/8.1/fighting_corruption_through_collective_action.pdfThis guide produced by the World Bank Institute,the UN Global Compact, a consortium ofleading NGOs, and private sector partners outlinesways to combat market corruption basedon proven “how-to” examples from many regionsand sectors. Cases from a diverse groupof countries are detailed in the guide, as wellas a range of tools that may assist users intailoring collective action frameworks to theirspecific circumstances and needs. (WBI/UNGC/CIPE/Transparency International/Global AdviceNetwork/Grant Thornton/Siemens, 2008)Business Fighting Corruption: ResourceCentre for Businesshttp://info.worldbank.org/etools/antic/index.aspThis website was developed as an anti-corruptionresource for business. It explores anddetails the constructive role that business canplay in fighting corruption and how this canbe done jointly with other companies andstakeholders—an approach called “collectiveaction”. Some organizations and individualsare already successfully using collectiveaction, and are often working with businessassociations, civil society, media, governmentdepartments and other stakeholders. Successfulcollective action results in increasedcompetition and market health, improvedtransparency, and a reduction in corruptionin many regions and business sectors. Societyhas benefited, as have the businesses thathave provided more reasonably priced andhigher quality goods and services—with thecostly, inefficiency-producing effects of corruptionreduced or eliminated.Collective Action – Building a CoalitionAgainst Corruptionhttp://www.unglobalcompact.org/docs/issues_doc/Anti-Corruption/CollectiveAction2010.pdfThis brief document produced by the WorldBank Institute Working Group outlines the roleof collective action in fighting corruption, andincludes information on the benefits of collectiveaction. A corresponding Internet portal isavailable at www.fightingcorruption.org. (WorldBank Institute, the Center for International PrivateEnterprise, Global Advice Network, GrantThornton, Siemens, Transparency Internationaland the United Nations Global Compact)Publish What You Paywww.publishwhatyoupay.orgPublish What You Pay is a global networkwith over 600 member civil society organizationsin more than 30 countries. Network8According to PACI, adherence to their principles does not create any additional legal obligation on behalf of the company (See https://members.weforum.org/pdf/paci/Legal_opinion.pdf).9. Zindera, Sabine: ‘Collective Action – Der gemeinsame Kampf gegen Korruption’ in Handbuch Compliance Management (Ed. Prof.Wieland,Dr.Steinmeyer, Prof.Grüninger).

17members have, together, created civil societycoalitions for collective action in theextractives sector. The network aims to helpcitizens of resource-rich developing countriesto hold their governments accountable forthe management of revenues from the oil,gas and mining industries. The campaignwas launched by George Soros and foundedby Global Witness, CAFOD, Open SocietyInstitute, Oxfam, Save the Children UK, andTransparency International UK.Transparency Internationalwww.transparency.orgTransparency International (TI) has been atthe forefront of the anti-corruption movementsince its formation in 1993. TI is a non-profit,independent, non-governmental organizationdedicated to increasing government accountabilityand curbing international and nationalcorruption. Through its international secretariatand network of over 90 national chaptersworldwide, TI works in a non-confrontationalway with governments, civil society and theprivate sector to develop means to combatcorruption. The development of the BusinessPrinciples for Countering Bribery followed TI’scoalition approach. These have become centralto TI’s engagement with the private sector andits efforts to help develop and raise corporatestandards of probity.International Business Leaders Forumwww.iblf.orgIBLF is an independent, not-for-profit associationof multinational and local companies andtheir leaders, focused on building responsiblebusiness solutions for a sustainable world.IBLF’s anti-corruption programmes havebeen supporting business leaders for nearlya decade in Russia, China, India and manyother countries. IBLF seeks to build andfacilitate partnerships between business,government and civil society to create anenvironment that is attractive to investors inboth the short- and long-term by addressingthe challenges posed by corruption.IBLF achieves this in a number of ways: Itprovides regular in-country forums for leadersand senior executives from business to exchangebest practices on improving corporategovernance and reducing corruption withintheir own companies and in the markets inwhich they operate; it informs the broaderbusiness community, government and civil societyof the economic and social benefits of thebest international business standards; it bringstogether companies in specific industries andmarkets in collective action approaches topromote responsible business practices; and itencourages and inspires the new generation ofstudents and young business leaders to adoptthe best standards of business ethics througheducational materials and mentoring.The World Economic Forum—Partnershipagainst Corruption Initiative (PACI)http://www.weforum.org/issues/partneringagainst-corruption-initiativePACI, initiated by leading CEOs from theWorld Economic Forum, was officiallylaunched in 2004. Using the PartneringAgainst Corruption—Principles for CounteringBribery (“PACI Principles”), which were derivedfrom Transparency International’s BusinessPrinciples for Countering Bribery as a coredocument, the PACI encourages member companiesto sign a support statement officiallyacknowledging their commitment to the PACIPrinciples. By signing the statement, companiescommit to “zero tolerance” of corruptionand bribery as well as to the development ofan internal implementation programme. Movingforward, the PACI continues to focus onpragmatic implementation mechanisms.United Nations Global Compactwww.unglobalcompact.orgIn 2004, a 10th Principle was added to theUnited Nations Global Compact, a multi-stakeholderinitiative, sending a strong signal thatthe private sector shares responsibility foreliminating corruption. The principle states:“Businesses should work against corruption inall its forms, including extortion and bribery.”The adoption of the 10th Principle commitsthe almost 9,000 Global Compact participantsnot only to avoid bribery, extortion and otherforms of corruption, but also to developpolicies and concrete programmes to addressthem. The United Nations Global Compactis a voluntary initiative with a mandatoryrequirement for business participants to disclose,on an annual basis, their performancein four issue areas (Anti-Corruption, HumanRights, Labour, and Environment).

18 Business Against CorruptionSector- and country-basedexamples of collective actionExtractive Industries TransparencyInitiativewww.eitransparency.orgThe Extractive Industries Transparency Initiative(EITI), announced in 2002 by the UK’s then-Prime Minister Tony Blair, aims to “strengthengovernance by improving transparency and accountabilityin the extractives sector.” The EITIis a multi-stakeholder coalition of governments,businesses, civil society, investors and internationalorganizations, and provides a standardmethodology for companies to follow whenthey make payments to governments, and forgovernments to disclose what they receive frombusinesses. This ensures the maintenance of aglobal standard by all implementing countries.EITI-compliant countries regularly publishall material payments made by extractiveindustries to governments and materialrevenues received from these industriesby the government. These are reconciledindependently by a trusted third party usinginternational auditing standards. The datais published with the third party’s opinionregarding the reconciliation of any discrepanciesthat may exist. This report may then beused by others in in-countries dialogues. Asof April 2011, the list of compliant countriesincludes Azerbaijan, the Central African Republic,Ghana, Kyrgyzstan, Liberia, Mongolia,Niger, Nigeria, Norway, Timor-Leste, andYemen. More than 20 other countries havesignalled intent to implement the EITI.The Convention on Business Integrity(CBi)—Nigeriawww.theconvention.orgThe Convention on Business Integrity (CBi) is anon-governmental organization created in 1997by a number of concerned business leaders inNigeria to combat corruption in the private andpublic sectors, with a vision to “create a societyof zero tolerance for corruption.” CBi membersinclude not only local and international companies,but also educational institutions andgovernmental departments. Among its 20 currentcorporate signatories are SAP, Accenture,Cadbury, Dunlop and Standard Chartered Bank.By signing on to the CBi, companies committo the values and rules of the Code ofBusiness Integrity, which contains sanctionsand incentives for participants. Though theCode is not legally binding, all parties committhemselves to a moral obligation.To join the CBi, companies must undergoa series of stages during which their past integrityis examined by a business peer reviewmechanism. CBi then provides assistance forcompanies to develop their internal auditingprocesses. In the last, critical stage before anassociation can receive full membership, anexternal audit is conducted to confirm thateffective integrity procedures are in place.The initiative has drawn interest fromgroups in Kenya, Rwanda, Uganda, Slovakia,Germany and the UK.FIDIC Code of Ethics and BusinessIntegrity Management Systemwww.fidic.org; www1.fidic.org/resources/integrityThe International Federation of ConsultingEngineers (FIDIC), an industry association thatrepresents the international business interestsof firms belonging to national memberassociations of engineering-based consultingcompanies, asks firms to comply with FIDIC’sCode of Ethics and Policy Statements in orderto be accepted as members. Furthermore,FIDIC has developed a comprehensive BusinessIntegrity Management System (BIMS)for consulting firms, which complements itsestablished Qualify Management Systems. Itrecommends that all its members implementthe BIMS within their operations.Global Principles of Business Ethics forthe Aerospace and Defence Industryhttp://www.asd-europe.org/site/fileadmin/user_upload/07_4PGlobalPrinciples_A4.pdfThe Aerospace Industries Association ofAmerica (AIA) and Aerospace and DefenceIndustriesAssociation of Europe (ASD) have jointlydeveloped these Global Principles of BusinessEthics for the Aerospace and Defence Industry(“Global Principles”). These Global Principlesare based on best practices, including the CommonIndustry Standards for European Aerospaceand Defence, and the Defense IndustryInitiative on Ethics and Business Conduct inthe US. The aerospace and defence industry’slong-term success depends on companies’

19upholding integrity in bidding, negotiatingand performing contracts. Companies subscribingto the Global Principles promise to behaveethically towards their customers, suppliers,competitors, employees and other stakeholders.The Global Principles highlight key issuesin the aerospace and defence industry thatmay impact on ethical business conduct. However,they are not an exclusive list of businessethics issues that a company may face, andcompanies are encouraged to give their staffguidance on ethical issues as appropriate toa particular company. It is intended that theGlobal Principles will continue to develop overtime to reflect current best practices.China Business Leaders Forum—CompaniesPartnering to Promote Transparencywww.cblf.org.cnDuring 2004, the International Business LeadersForum, in partnership with the RenminUniversity of Beijing and a group of businessleaders from domestic and internationalcompanies, established the China BusinessLeaders Forum (CBLF). Its mission is to “enablecompanies (both Chinese and foreign)operating in China to work collectively toachieve sustainable improvement in corporategovernance that reflect internationalbusiness standards.” It provides a facilitythrough which business leaders in China canaddress collectively issues of responsible businessstandards across a wide range of businesstopics. In January 2011, CBLF launcheda new three-year ‘Integrity and Transparencyin Business Initiative’ to mobilize businessto fight corruption in support of the government’sincreased commitments to action.Collective action of this nature recognizesthe critical importance of dialogue between Chineseand international companies in improvingpractices, as well as the reality that individualcompanies can make only limited progress ontheir own. Through their joint efforts, trust andconfidence within the business community isbeing built and strengthened, making the businesscommunity a more influential partner inits relationships with other sectors.Case examples of specificprojects utilizing collective actionIntegrity Pact at Berlin AirportA German principal solicited bids for the constructionof a new airport south of Berlin. Thebidding companies were required to ensure thattheir suppliers adhered to an agreed-upon set ofprinciples and were signatories to the contract.Here, the involvement of third-party monitors ofthe tendering process helped re-start the tenderbidding process, which had been suspended becauseof the abnormally high costs associatedwith the originally submitted bids.World Bank (http://info.worldbank.org/etools/docs/antic/Whole_guide_Oct.pdf)Local and Municipal Integrity Pacts inColombiaIn Colombia, mayors, governors and otheradministrators have, upon the establishmentof a new initiative, signed loctal procurementtransparency pacts with members of theprivate sector. Such pacts were witnessed bymembers of the national government. Theseactions have increased the credibility andtrust in government initiatives and promotedfairer competition among bidding companies.With regard to the procurement law reformin Colombia, businesses and civil society—which were provided with the opportunity tocomment on the draft law—provided key informationon the challenges they faced and weregranted oversight on the process of procurementlaw reform. This led to the introductionof more transparency procurement practices,greater competition in the procurement process,and greater assurances for the evaluationof investments.World Bank (http://info.worldbank.org/etools/docs/antic/Whole_guide_Oct.pdf)India’s Defence Procurement DirectiveThe 2006 Defence Procurement Procedureof the Government of India requires, amongother things, the use of Integrity Pacts forall government contracts worth more than 1billion rupees (US $22.5 million). The pact is abinding agreement between the governmentagency asking for bids, and bidders for specificcontracts. The government has promisedit will not accept bribes during the biddingprocess, and bidders promise they will notoffer bribes.Transparency International (See the full report, availableat http://www.defenceagainstcorruption.org/.)

20 Business Against CorruptionTools and resourcesICC Rules of Conduct toCombat Extortion and Briberyhttp://iccwbo.org/policy/anticorruption/id870/index.htmlFirst published in 1977 and last revised in 2005, theInternational Chamber of Commerce (ICC) Rules of Conductto Combat Extortion and Bribery outline the basicmeasures companies should take to prevent corruption.These Rules are intended as a method of self-regulationby international business: They are of a general nature,constituting what is considered good commercial practicein matters to which they relate, but are without legaleffect. Since their initial publication in response to thewidely publicized bribery scandals of the mid-1970s, theRules have set markers for the business community andhave been adopted by many companies worldwide.The ICC has established a Commission on Anti-Corruption,whose objectives are to:• Update the ICC Rules of Conduct onExtortion and Bribery,• Prepare a briefing paper on the UN Convention againstCorruption to promote its implementation worldwide,• Explore the possibility of establishing facilities tocollect information on the solicitation of bribes,• Develop a practical ICC tool to guide companies, andespecially SMEs, in addressing anti-corruption issuesand compliance procedures, and• Continue to promote the use of ICC’s publicationFighting Corruption: A Corporate Practices Manual (apractical handbook for managers in large multinationalcompanies as well as SMEs that administer corporatecompliance programmes in line with the Rules).Business Principles for Countering Briberyhttp://www.transparency.org/global_priorities/private_sector/business_principlesThe development of the Business Principles for CounteringBribery (Business Principles), initially published in 2003and revised in 2009, was undertaken by TransparencyInternational in partnership with Social AccountabilityInternational and a Steering Committee drawn from business,academia, trade unions and other non-governmentalbodies. The Business Principles are a practical and comprehensivemodel of good practice in the area of anti-bribery.They provide a detailed elaboration of one critical aspect ofa code of conduct. Beyond the strict prohibition of bribery,the Business Principles make it a fundamental requirementto implement a programme to counter bribery. TI has developeda full suite of tools to support the implementationand monitoring of the Business Principles.The 2009 edition “charts new territory by placing greateremphasis on public reporting of anti-bribery systems and inrecommending that enterprises commission external verificationor assurance of their anti-bribery programme.”First to Know—Robust InternalReporting Programmeshttp://www-dev.iblf.org/resources/general.jsp?id=39This brief guidebook provides information on recent legaldevelopments, voluntary initiatives and emerging bestpractices in the areas of reporting, making disclosures, andprotecting staff prepared to speak up when malpracticesoccur within a company. It was published by TRACE, ISISAsset Management and the International Business LeadersForum. Additional resources can also be found on the TRACEwebsite (https://secure.traceinternational.org/Default.asp?).UN Global Compact website(www.unglobalcompact.org)• The Communication on Progress: http://www.unglobalcompact.org/COP/communicating_progress.html• The Differentiation Programme: http://www.unglobalcompact.org/COP/differentiation_programme.html• The Anti-Corruption Reporting Guidance: http://www.unglobalcompact.org/docs/issues_doc/Anti-Corruption/UNGC_AntiCorruptionReporting.pdf• UN Global Compact Management Model: http://www.unglobalcompact.org/docs/news_events/9.1_news_archives/2010_06_17/UN_Global_Compact_Management_Model.pdf• Other tools on Anti-Corruption: http://www.unglobal-compact.org/Issues/transparency_anticorruption/Anti-Corruption_Guidance_Material.htmlIntergovernmental anti-corruptioninstrumentsUnited Nations: The UN Convention againstCorruption(http://www.unodc.org/unodc/en/treaties/CAC/index.html)OECD• Convention on Combating Bribery of Foreign PublicOfficials in International Business Transactions (http://www.oecd.org/document/21/0,3746,en_2649_34859_2017813_1_1_1_1,00.html)• Recommendation of the Council for Further CombatingBribery of Foreign Public Officials in InternationalBusiness Transactions, 2010 (http://www.oecd.org/dataoecd/11/40/44176910.pdf)• Guidelines for Multinational Enterprises (http://www.oecd.org/department/0,3355,en_2649_34889_1_1_1_1_1,00.html)

21• The Financial Action Task Force on Money Laundering(FATF) The Forty Financial Action Task ForceRecommendations (http://www.fatf-gafi.org/document/28/0,3343,en_32250379_32236930_33658140_1_1_1_1,00.html)• Organization of American States Inter-American Conventionagainst Corruption (IACC) (http://www.oas.org/juridico/english/treaties/b-58.html)• Council of Europe• Council of Europe Civil Law Convention on Corruption(http://conventions.coe.int/treaty/en/treaties/html/174.htm)• Council of Europe Criminal Law Convention on Corruption(http://conventions.coe.int/treaty/en/treaties/html/173.htm)• European Union The European Union Convention on theFight against Corruption Involving Officials of the EuropeanCommunities or Officials of Member States (http://europa.eu/legislation_summaries/fight_against_fraud/fight_against_corruption/l33027_en.htm)• African Union Convention on Preventing and CombatingCorruption and Related Offences (http://www.africa-union.org/official_documents/Treaties_%20Conventions_%20Protocols/Convention%20on%20Combating%20Corruption.pdf)Global initiatives against corruption• Transparency International (http://www.transparency.org/global_priorities/private_sector/business_principles)• International Chamber of Commerce (www.iccwbo.org)• World Economic Forum—Partnership against CorruptionInitiative (http://www.weforum.org/issues/partneringagainst-corruption-initiative)Sector-wide initiatives againstcorruption (examples)• International Federation of Consulting Engineers(FIDIC) Code of Ethics and Policy Statements (http://www1.fidic.org/about/ethics.asp)• International Council on Mining and Metals (ICMM)Sustainable Development Charter, ICMM TenPrinciples (http://www.icmm.com/our-work/sustainabledevelopment-framework/10-principles)• “Publish what you pay” (www.publishwhatyoupay.org)• UNICORN, Trade Union Anti-Corruption Network (http://www.againstcorruption.org/)• The Extractive Industry Transparency Initiative(www.eitransparency.org)General anti-corruption links• UN Global Compact (www.unglobalcompact.org)• OECD (www.oecd.org)• International Business Leaders Forum (www.iblf.org)• Transparency International (www.transparency.org)• Avoid Corruption—guide for companies, publishedby the Confederation of Danish Industry(http://di.dk/english/Pages/English.aspx)• Facing up to Corruption, published by Control RisksGroup (http://www.control-risks.com/pdf/corruption%20sequel2003.pdf)• TRACE International (www.traceinternational.org)• United Nations Office for Drug Control and CrimePrevention (www.unodc.org)• Anti-Corruption Gateway for Europe and Eurasia(www.nobribes.org)• Global Witness (www.globalwitness.org)• Center for International Private Enterprise(www.cipe.org)• The International Chamber of Commerce (www.iccwbo.org): Fighting Corruption: A Corporate Practices Manual• Ethics Resource Center(www.erc.org): Offers training of ethics officers and staff.• Public Concern at Work (www.pcaw.co.uk): A consultancy,it provides guidance and practical training for companies,advises governments and runs a confidential helpline for employees.In 2005, Public Concern at Work published WhistleblowingAround the World: Law, Culture and Practice.• Global Reporting Initiative (www.globalreporting.org) providescompanies with a comprehensive reporting framework.• FTSE4Good (http://www.ftse.com/Indices/FTSE4Good_Index_Series/Downloads/FTSE4Good_Countering_Bribery_Criteria.pdf):Criteria on countering bribery• Business Fighting Corruption(www.fightingcorruption.org)

The Ten Principles of theUnited Nations Global CompactHuman rightsPrinciple 1Principle 2Businesses should support and respect the protection ofinternationally proclaimed human rights; andmake sure that they are not complicit in human rights abuses.LabourPrinciple 3Principle 4Principle 5Principle 6Businesses should uphold the freedom of association and theeffective recognition of the right to collective bargaining;the elimination of all forms of forced and compulsory labour;the effective abolition of child labour; andthe elimination of discrimination in respect of employmentand occupation.EnvironmentPrinciple 7Principle 8Principle 9Businesses should support a precautionary approach toenvironmental challenges;undertake initiatives to promote greater environmentalresponsibility; andencourage the development and diffusion ofenvironmentally friendly technologies.Anti-corruptionPrinciple 10Businesses should work against corruption in all its forms,including extortion and bribery.Published by the UN Global Compact OfficeContact: unglobalcompact@un.orgMay 2011 | 0.0M