National Round Table Promoting Business Integrity in

Jordan : Role of the Public and the Private Sectors

Organized by the MENA-OECD Investment Programme in cooperation

with the Jordanian Anti-corruption Commission

Intercontinental Hotel, Amman, JordanFebruary 4, 2013

Working Group 2: Private Sector Civil Society François VinckeLawyer, Member of the Brussels BarICC Corporate Responsibility and Anti-corruption Commission

1.- HomeworkPromoting business integrity is intricate and complexBefore starting a dialogue, do your homework within the

business associations (national and sectoral)Analyze in depth where business stands on integrityDo not forget to have the SME’s on board and listen

carefully to their needsDo not come to the dialogue with empty hands: come

with your own proposals, based on your own findingsAt the ICC, we first established our own Rules on

combating Corruption and then started our dialogue

2.- Building TrustOnce you have established your proposals , you will need to create an

atmosphere of trust with all the participants in the dialogue (authorities and civil society)

• To build the conditions for a real dialogue, one needs to invest in genuine, thorough relations with all the participants. Know the persons you have in front of you, so that everybody considers the other as creditworthy

At the ICC, we sought extensive contact with the OECD Working Group on Bribery, the Council of Europe, the UNODC, the European Commission and more recently the G20. Each organization requires lots of attention and care and each kind of contact is different

3.- Effective and concrete proposalsAs I said: do not come with empty hands: come with effective

and concrete proposals, which will show your commitment to fighting corruption in real terms

Not resounding speeches on the need to fight corruption but effective, practical measures

Make proposals of which you know they can be realized Go for practical actionOne of first areas is awareness raising and training and

education

4.- Step by stepOne has to learn to be patient: not everything can be

realized in one goGo step by stepA small achievement is better than a total failure on a

grand projectDo not let you be disheartened by opposition to your

proposals, there will be opposition (cynicism) in any case

5.- An Organized Dialogue Often one speaks of an “institutionalized” dialogueI am not sure this is the best formula: rather go for a

regular, continuous and deep dialogue, whereby you build on a strong basis

Dialogue should be systematic rather than institutionalized

For a SME, which wants to grow, it is important to have a genuine ethics and compliance profile

6.- EnforcementThe most difficult area for a constructive dialogueTry to engage the judiciary on a constructive, positive and

open dialogueAn exchange of information on company practice is

probably an interesting base of departureMaybe the judiciary will want to proceed with test cases

to prioritize the most urgent circumstances

7.- What ICC does (I)1. - We have recently rewritten our self

regulatory Rules on Combating Corruption (2011)

 http://www.iccwbo.org/uploadedFiles/ICC/poli

cy/business_in_society/Statements/ICC_Rules_on_Combating_Corruption_2011edition.pdf

 2. - The Rules are supported by Guidelines

on Whistleblowing (2008) http://www.iccwbo.org/uploadedFiles/ICC/poli

cy/business_in_society/Statements/ICC_Guidelines_on_Whistlelowing_ENG.pdf

8. What ICC does (II)3. - Essential in the building of a prevention plan is

the Guidelines on Agents, Intermediaries and other Third Parties (2010)

http://www.iccwbo.org/uploadedFiles/ICC/policy/business_in_society/Statements/195-11%20Rev2%20ICC%20Third%20Parties%20FINAL%20EN%2022-11-10.pdf

4. - ICC and a number of other organisations have prepared, under the title RESIST (2011) around 20 scenarios showing companies how to resist solicitation/extortion in real life

English: http://www.iccwbo.org/uploadedFiles/RESIST2_Oct2010.pdfArabic:

http://www.iccwbo.org/uploadedFiles/ICC/policy/business_in_society/pages/RESIST_AR_text.pdf

9.- What ICC does (III)5. - The ICC Commission on Corporate Responsibility and

Anti-corruption is preparing Guidelines on Gifts, Hospitality and Expenses and an ICC Anti-corruption Clause

6.- A Handbook titled Fighting Bribery, a Corporate Practices Manual has been issued in 1999, a second edition was published as Fighting Corruption, a Corporate Practices Manual in 2003 and a third edition was published as Fighting Corruption International Corporate Integrity Handbook in 2008. The latter version can only be obtained as an e-book.

7.- ICC Anti-corruption Clause