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Industry Agenda

Partnering AgainstCorruption Initiative

Global Principles forCountering Corruption

January 2014

Application


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World Economic Forum2014 - All rights reserved. No part of this publication may be reproduced ortransmitted in any form or by any means, includingphotocopying and recording, or by any informationstorage and retrieval system.

The views expressed are those of certain participants inthe discussion and do not necessarily reect the viewsof all participants or of the World Economic Forum.

REF 030114


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Contents Foreword

3 Foreword

4 A Call to Action against Corruptionby Global Business Leaders

5 PACI Principles for CounteringCorruption

6 Implementation Guidelines

8 PACI Membership Application

10 Annex I: Implementation Survey

11 Annex II: PACI MemberCode of Conduct

The PACI Principles for Countering Bribery were formulated in 2004 by a coregroup of chief executives from the World Economic Forums Industry Partnershipprogramme who were concerned about the adverse impacts of corruption

on business and society, and the need for a coordinated response. The PACIPrinciples were then, and remain to this day, anchored by a CEO pledge to zerotolerance for bribery in all its forms.

Ten years later, the Partnering Against Corruption Initiative (PACI) operates asa global platform centred on these Principles and works to enable companiesto maximize their collective impact in the ght against corruption. Working incollaboration with key stakeholders from government, international organizationsand civil society, PACI strives to ensure a level playing eld for businesses byghting corruption and creating markets based on genuine competitive forces.

The CEO-level commitment to the PACI Principles ensures that PACI membersare committed at the highest level of their organizations, while the PACI TaskForce a dedicated group of senior executives who oversee compliance, ethics,strategy and various other corporate functions creates a safe space for peerengagement to implement the core tenets behind the PACI Principles, improvesorganizational compliance and raises overall business standards.

The PACI Principles have been revised and updated in 2013, and retitled thePACI Principles for Countering Corruption . The revised PACI Principles expandthe focus beyond bribery and represents a natural evolution of the objectivesof the PACI community. The Principles are intended to be a guiding frameworkfor businesses ready to assume a leading role in combatting corruption in all itsforms. The PACI Principles commence with six core aspirational principles thatunderpin the continuous drive for transparency, integrity and ethical businessconduct. They also encompass a set of implementation guidelines which outlinekey measures companies should embrace to translate their commitments intoaction.

Recognizing the power of multistakeholder, collaborative action in transformingthe global, regional and industry agenda on corruption, the PACI Principles alsoserve as a call to action for businesses around the world to join collective actioninitiatives, which increase public trust in business, deliver fair markets and levelthe playing eld by ghting corruption.

Global Principles for Countering Corruption


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A Call to Action against Corruptionby Global Business Leaders

Fighting corruption in all its forms not only advances thedevelopment and well-being of society, but also makesbusinesses stronger, more resilient to risk, more ethicaland, ultimately, more sustainable. As businesses confrontcontinuous pressure to grow in challenging economicconditions and markets, tackling corruption also shapesthe global environment in which we live, interact and dobusiness for the better.

Our united effort begins with a pledge to conduct

businesses with zero tolerance towards corruption. Byimplementing anti-corruption programmes in accordancewith the PACI Principles for Countering Corruption, and byhelping business partners lift their own ethical standards, westrive to build a genuine community-wide culture of integrityand one in which corruption is not tolerated.

We consider our roles as global business leaders asextending beyond ensuring organizational compliance withthe prevailing laws. Leadership responsibility means thatwe will endeavour to be ambassadors for anti-corruptionactivities, and bring together those companies that sharethese high ethical standards with the common purpose ofghting corruption in the private and public spheres.

By bringing individual businesses into an alliance of like-minded organizations, and by creating a collaborative andsustained process for cooperation among all stakeholders,collective action of this type increases the credibility andimpact of our individual actions, and levels the playing eldamong competitors so that our businesses can grow andthrive on the basis of fair competitive forces.

Our vision is of a world free of corruption, where allcompanies have a fair and equal opportunity to gain new

markets and grow their business. PACI is the operationalplatform through which we as global business leadersengaged with the World Economic Forum seek to raisebusiness standards and engage in collective action toeliminate corruption across global markets. We urge ourcolleagues from around the world to join PACI and take anactive part in this important endeavour.

Partnering Against Corruption Initiative


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PACI Principles for CounteringCorruption

As global business leaders, we have individual andorganizational responsibilities to make a strong and activecontribution to the ght against corruption. By committing tothe PACI Principles for Countering Corruption , we join forcesto support a global, cross-industry, multistakeholder anti-corruption initiative established to raise business standardsand to build a competitive, transparent, accountable andethical business environment.

We and our organizations pledge to:

i. Set the tone at the top through a visible and activeleadership commitment to zero tolerance of corruption inall its forms

ii. Build an internal culture of integrity that encourages,recognizes and provides positive support for ethicalconduct

iii. Foster transparency throughout our organization and inour interactions with our stakeholders

iv. Comply with applicable laws and regulations in the jurisdictions where we operate and transact our business

v. Encourage our business partners to uphold the sameethical standards that we observe

vi. Engage in PACI and other collective action initiativesto bring a coordinated response to the challenge ofcorruption, whether in specic geographies or industrysectors

To translate these Principles into concrete and measurableactions, we also commit ourselves and our organizations tothe implementation and ongoing development of an effectiveanti-corruption programme, which incorporates and isbased on the Implementation Guidelines detailed in thefollowing pages.

CEO Signature:

Date:

Place:

Full Name:

Position:

Company:

Full Address:

E-mail:

Direct Telephone:

Direct Fax:

Assistants Name:

Assistants E-mail:



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Implementation Guidelines

The following section outlines the core requirements thatbusinesses should meet, at a minimum, when designing andimplementing their anti-corruption programme.

An effective programme comprises the entirety of anenterprises anti-corruption efforts, specically including itscode of ethics, policies and procedures, risk assessment,internal and external communication, training, guidance,internal controls, monitoring and oversight.

The programme should cover corruption in all its forms.It should be tailored to reect the enterprises particularbusiness circumstances, taking into account its size, thenature of the business, potential risks and the location ofoperations. The business should ensure that it is informedof all matters material to the effective development andimplementation of the programme through appropriatemonitoring activities, communications with relevantparties and by observing emerging industry practices. Thebusiness should also actively engage employees in theimplementation of the programme.

The anti-corruption programme should address businesstransactions that are carried out either directly or throughthird parties.

An effective programme should incorporate the following:

1. Leadership and responsibilities The board of directors (or equivalent bodies) andexecutive management have ultimate responsibility forthe programme and should demonstrate strong, explicit,visible and active commitment to its implementation. Thebusiness should make clear that compliance with theprogramme is mandatory and the duty of all individuals

at all levels of the business and encourage suchperformance.

The chief executive ofcer (or equivalent) should seethat the programme is carried out consistently with clearlines of authority and adequate resources. Authorityfor oversight and implementation of the programmeshould be assigned to one or more senior ofcers withan adequate level of autonomy, sufcient resourcesand unfettered access to the chief executive ofcer andboard of directors (or equivalent bodies).

2. Risk assessment and continuous improvement The business should design and improve its programmebased on periodic risk assessment, through which itidenties the most prevalent forms of corruption to whichit is exposed. Such risk assessment should be reviewed

and updated periodically. Executive managementshould monitor the programme and continuously reviewits suitability, adequacy and effectiveness, and shouldimplement improvements as appropriate.

Where risk assessments indicate institutional or systemicweaknesses related to corruption in a business sector ormarket, the enterprise should consider addressing suchrisk through collective action.

3. Policies, procedures and internal controls The business should establish anti-corruption policies,procedures and a system of internal controls that reectits risk assessment and risk prole.

Policies and procedures should emphasize zerotolerance for corruption, and outline expectations ofbehaviour as they relate to: bribery (direct and indirect);facilitation payments; gifts, travel, entertainment andhospitality; and charitable and political contributionsand sponsorships. Businesses should work towardsthe comprehensive elimination of facilitation payments,in recognition that these are prohibited by domesticlaws and many international legal regimes. Businessesshould advocate, through collective action or othermeans, for the enforcement of such applicable laws inthose jurisdictions where enforcement is weak or non-existent. Procurement policy should ensure that suppliersand contractors are selected through fair, honest andtransparent processes.

Effective nancial and internal controls should alsobe established to ensure the documentation andmaintenance of fair and accurate books and records.

The business should conduct periodic reviews,

monitoring and testing of its policies, procedures andinternal controls to assess compliance and allow forcontinuous improvement.

4. Training and communication The programme should be communicated to allemployees of the business and, as appropriate, to thirdparties. Directors, management, relevant employees andrelevant third parties should be provided specic trainingthat is tailored to their needs and circumstances. Thebusiness should publicly disclose its commitment to anti-corruption and be open to receiving communications

from stakeholders.



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5. Reporting of complaints The programme should provide secure and accessiblechannels through which employees and others canobtain advice, raise concerns and report suspiciouscircumstances in condence, and without reprisal.

The business should make clear that compliance withthe programme is mandatory and that no employee will

suffer demotion, penalty or other adverse consequencesfor refusing to pay bribes, even if this may result in theloss of business.

The business should respond quickly and appropriatelyto instances of veried unethical and corrupt behaviour.It applies appropriate sanctions for violations ofthe programme, up to and including termination inappropriate circumstances.

6. Business relationships The business should implement an anti-corruptionprogramme in all business entities over which it haseffective control. Where the enterprise does not haveeffective control, it should encourage all business entitieswith which it has a signicant business relationship, orover which it has signicant inuence, to adopt an anti-corruption programme.

Using a risk-based approach, the business shouldconduct reasonable and proportionate due diligencebefore entering into a business relationship with athird party, and should update such due diligence atreasonable intervals. The business should implement riskmitigation measures to address potential corruption risks

that may have been identied in the course of the duediligence process. Such risk mitigation measures could on the basis of a risk-based approach include anti-corruption representations and warranties in contractsand reasonable audit rights, with respect to the thirdpartys records. Monitoring and review of third-partyrelationships should also be conducted on a risk-basedapproach and at reasonable intervals.

An in-depth guide to the PACI Principles for CounteringCorruption is available in conjunction with this documentand to be used by members at their discretion in theimplementation of these principles.



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PACI Membership Application

PACI membership is generally restricted to Members of the World Economic Forum. Both the membership application andthe PACI Principles for Countering Corruption must be signed by the chief executive ofcer or equivalent company ofcer.

applies to be a Member of World Economic Forums Partnering AgainstCorruption Initiative (PACI).

In support of the application, we submit the signed PACI Principles for Countering Corruption and the information below:

1. Company Information

Company:

Company Type: Public Private State-Owned

Is the company a subsidiary? Yes No

If yes, parent name:

Group Revenue: Group Employees:

Sector:

Full Address:

Website:

Main Telephone: Main Fax:

2. Disclosure of Relevant Information

Companies wishing to join PACI must disclose on company letterhead and as a separate attachment to thisapplication:

Any convictions or agreements with regulators or government agencies in relation to bribery or corruption by theapplicant, its employees or third parties associated with the applicant in the last 10 years

Any current or pending investigations by regulators or government agencies in relation to bribery or corruption by theapplicant, its employees or third parties associated with the applicant

Any material allegations of bribery or corruption which the applicant is currently investigating Any fraudulent or criminal convictions or investigations during the last 10 years which was/is of such signicance that

it may impact the reputation of the World Economic Forum, PACI or other PACI members through association with theapplicant

Companies should also indicate any remediation being taken to address these issues. All submissions are strictlycondential.

Full name of company



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Annex II: PACI Member Code of Conduct

1. Condentiality

The Forums independence and integrity are of utmostimportance to the preservation of its unique status and closerelationship with Forum Members and Partners.

Member companies agree to safeguard these principlesand to refrain from any activity that would conict with thesecentral principles.

Member companies expressly agree that any informationabout participants or preparations for Forum activitiesprovided in the context of the membership is strictlycondential and for the sole purpose of planning formeetings. Proprietary information may not be transmitted inany form to outside parties.

2. Non-exclusivity

Membership does not grant or imply the Forumsendorsement or sponsorship of a Members goods orservices or otherwise express any preferences for, orpromotion of, the Members goods or services in themarketplace.

3. Communications Guidelines

Member companies cannot cooperate with third-partypublic relations rms in matters related to the membershiprelationship, including press matters.

Due to the independent and non-commercial nature of theForum, Members agree to coordinate with the Forum priorto any public relations or publicity initiatives linked to theirmembership.

Member companies must obtain the express approval ofthe Forum before engaging in sending out any pre-meetingpress releases or communications containing informationrelated to the meeting or project in question and in usingthe Forums name or reference to its activities in print, onthe internet or in any other form of media, or for externalmarketing or advertising purposes.

To avoid any appearance of commercialization of the Forumactivities, Member companies commit to the greatestrestraint in conducting any promotional activity outside the

regional meeting or Annual Meeting venue.

As requested by participants, Member companies arediscouraged from systematically distributing material to hotelrooms.

4. Use of Logos and Other Promotional Material

Member companies must refrain from any promotionalactivity which goes against the non-commercial spirit andatmosphere of Forum activities.

Use of the Forums logo by Member companies on any typeof document or in their promotional, marketing, advertisingand/or public relations activities, whether printed or inelectronic format, is not permitted. The Forum must not

endorse another organization or its products.

The Forum does not accept the presence of any logoor banner from Member companies in the context of itsactivities (such as sessions, media meetings and hostedmeetings) except in special cases of partnership at theForums sole discretion.

Global Principles for Countering Corruption 11


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