BulletProofBlog the blog on crisis communications

Each week, Bulletproof Blog™ features exclusive interviews with thought leaders on issues of critical importance to companies and countries. This week, with public and private sector corruption issues making headlines and raising regulators’ ire like never before, we interview Susan Côté-Freeman of Transparency International.

Ms. Côté-Freeman is an expert in anti-corruption control mechanisms with a strong grasp of the best practices currently being utilized by companies and countries. As the manager of Transparency International’s Business Principles for Countering Bribery Initiative, who works with business to help combat unethical practices, she shared her insights with Bulletproof™:

What roles do internal and external communications play in an effective anti-corruption program?

Susan Côté-Freeman: That’s a great question because many companies still struggle with how communications can best support an effective anti-corruption program. Internally, you want your employees, contractors, subsidiaries, and other business partners to understand that there are anti-corruption controls in place and precisely what they entail. Providing training is also a key aspect of the effort because it outlines and formalizes the bounds of acceptable behavior.

Externally, companies must make their commitment to honest and ethical business practices known for several reasons. Investors and other stakeholders want to know that the company is taking action to protect itself in an aggressive regulatory environment. Potential clients need to know they can trust the entities they do business with. And having a strong anti-corruption program in place provides a strong fallback position that both regulators and the general public will appreciate if a violation does occur.

Last year, we at Transparency International published a study of 500 major companies around the world – and many in high-risk industries, such as oil and gas – to gain some insight into what information they publicly report on their policies and management systems to counter corruption. We found that the majority of companies were not communicating systematically on bribery and corruption. So, we’ve partnered with the UN Global Compact to develop guidance that companies can use to enhance anti-bribery reporting and make it more meaningful for stakeholders.

What are the most common mistakes companies make when seeking to establish and implement anti-corruption compliance programs? How can those mistakes best be avoided?

Susan Côté-Freeman: We haven’t done specific research in this area, so my answer is by no means scientific. But that being said, a big challenge companies often face is a misalignment between the spirit of the anti-corruption program and a company’s primary business objectives. The company policy may be “zero-tolerance” toward bribery and corruption, but at the same time, the sales force is rewarded based on the hard numbers and is often put in the difficult position of having to choose between the company’s commitment to ethical business practices and winning new business.

In this regard, the importance of a corporate culture that truly values and rewards honesty and integrity cannot be understated. Employees need to know that they won’t be punished for refusing to engage in corrupt behavior and that they have internal channels by which to report possible malfeasance. Simply put, they need to know that they can turn away from a deal if they have even the slightest inkling that it may be tainted.

What’s next on the anti-corruption landscape? Are there issues emerging on the horizon that all companies need to be aware of?

Susan Côté-Freeman: There’s no question that the anti-corruption enforcement environment is changing rapidly. In recent years, we’ve seen unprecedented regulatory activity in the U.S., in particular, and in Germany as well – and I think that, hopefully, we’re going to see that mirrored in other nations around the world. We’ve reached a point where global companies, no matter where they operate, need to take the issue seriously or face the prospect of ever-increasing government and marketplace penalties.

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Larry Smith is Senior Vice President of Levick Strategic Communications, the nation's top crisis communications firm, and a contributing author to Bulletproof Blog. Connect with Levick on Twitter: @Levick.