BulletProofBlog the blog on crisis communications

Last week, a coalition of investors who manage more than US$1.6 trillion in assets wrote to 21 major corporations around the world to request enhanced reporting of anti-corruption measures. As George Dallas, Director of Corporate Governance at F&C Management and a signatory to the letter, put it, “As investors, we believe that bribery and corruption are incompatible with good corporate governance and harmful to the creation of value. Therefore, we expect the companies that we invest in to have robust programs to manage corruption in their firms and supply chains, and to ensure those programs measure up to respected international standards.”

With massive growth in nearly every measurable area of regulatory anti-corruption enforcement, shareholders in some of the world’s largest and most successful companies are coming to the conclusion that corruption presents a significant bottom line liability – and they want to know precisely how the companies they own are working to mitigate this ever-increasing risk. Just as governments around the world are already making anti-corruption communications programs lynchpins of their efforts to attract increased foreign direct investment, public companies must now do the same or risk the ire of shareholders – and potential shareholders – that are increasingly sensitive to how bribery and other dishonest business practices can damage their portfolios.

Further evidence of the need for vigorous communications that both support and publicize anti-corruption programs is found in the World Economic Forum Partnering Against Corruption Initiative’s (PACI) “Principles for Countering Bribery, which explicitly demands that a corporate signatory:

• “Establish effective mechanisms for internal communication of the program;”


• “Publicly disclose its policy for countering bribery;” and


• “Be open to receiving communications from relevant interested parties with respect to its policy for countering bribery.”

With investors providing the “why” and the good governance community providing the “what,” it’s time for companies examine the “how” of anti-corruption communications.  Queue the United Nations Global Compact (UNGC) and Transparency International’s (TI) recently issued “Reporting Guidance on the 10^th Principle Against Corruption” – an outline of emerging best practices for communicating a commitment to the UNGC’s 10^th Principle, which states that “Businesses should work against corruption in all its forms, including extortion and bribery.”

From policy development and program implementation to compliance monitoring and improvement processes, the UNGC and TI have provided a detailed assessment of how best to provide the information that stakeholders are seeking when evaluating corporate anti-corruption initiatives. And with stepped enforcement of the U.S. Foreign Corrupt Practices Act (FCPA), the recent enactment of the UK Bribery Act 2010, and countless nations seeking to mirror these efforts, such guidance couldn’t have come at a better time.

Richard S. Levick, Esq., President and CEO of Levick Strategic Communications, sits on the board of the World Economic Forum’s Partnering Against Corruption Initiative (PACI). He is also a contributing author to Bulletproof Blog. Connect with him@richardlevick.