*Does your company have requirements regarding independence of board members (e.g. minimum number of members or minimum ratio of the board; limit on the number of years serving)?
Yes, please specify
No
I don’t know
*Please provide any character-based board qualification requirements, or incompatibilities, relating explicitly to integrity or ethics? If this question is left blank, it will be assumed there are no character-based board qualifications relating explicitly to integrity or ethics (open text)
Are the roles of board chair and CEO separate?
Yes
No
I don’t know
Other
*Does the board have powers to appoint or remove the CEO?
Yes, please specify whether alone, jointly with the state or subject to state approval?
No
I don’t know
Other
Your company’s frameworks and standards for integrity
How clearly do relevant national laws, regulations, bylaws or governance codes establish expectations and requirements for your company’s actions and responsibilities in areas of integrity and anti-corruption (including for internal control, risk management, compliance etc.)?
Very clearly
Clearly
Somewhat clearly
Not at all clearly
I don’t know
Does your company have the following codes or programmes in place that support integrity and anti-corruption? If the question is left blank, it will be assumed that your company does not have any such codes or programmes.
A code of ethics
A code of conduct
A code of compliance
A specific anti-corruption or integrity programme or strategy
Other (please describe)
Please briefly provide further information about such codes or programmes, including whether they were required or established voluntarily, the standards on which they are based (e.g. IIA, COSO, OECD, IFAC, UNCAC, etc.), the goals of the codes/rules, and mechanisms for their implementation and monitoring.
Does your company have particular rules in the following areas?
Conflict of interest
Lobbying
Political party financing or engagement
Charitable contributions and sponsorships
Asset/income disclosure
Public procurement (as bidder)
Public procurement (as procurer of goods and services)
None of the above/not applicable
(Conditional question: IF public procurement as procurer selected) When your company acts as a public procurer (to procure goods and services), is it subject to ordinary government procurement rules?
Yes
No
I don’t know
NA
Other (please specify)
(Conditional question: IF public procurement selected as bidder) When your company participates in public procurement bids (i.e. to act as the supplier of goods and services to other parts of the public sector), is it subject to competitive bidding on an equal footing with other firms?
Yes
No
I don’t know
NA
Other (please specify)
Company arrangements and approaches to manage integrity and anti-corruption
Operational arrangements and approaches
Do you have any of the following, or similar, specialised board committees related to integrity and anti-corruption matters of your company?
Audit
Compliance
Ethics
Risk management
Procurement
Remuneration
Other similar, please specify
No specialised committees
If your company has the following units or functions, please indicate which of those have significant responsibility for promoting and overseeing integrity or integrity policies (relating to risk, controls, compliance, ethics or anti-corruption mechanisms)? [If the significant responsibility is evenly shared between more than one unit/function, you may select more than one. This question does not refer to the responsibilities of the board in this respect.]
Independent integrity department within your company (e.g. Compliance Unit, Risk Unit, Sustainability Unit)
In-House Legal Department
Internal Audit Department
Internal Controls Department
Internal Human Resources Department
Separate Legal Entity or Special Purpose Vehicle
External Professional Service Provider or Consultant
Other [please specify]:
To whom do those units/functions with significant responsibility for integrity report to? (please check all that apply)
Chairperson of the Board
CEO/President/Managing Director
Board Member
Non-Executive Director
Chief Financial Officer/Treasurer/Comptroller
Chief Audit Executive
Chief Compliance Officer
Chief Risk Officer
Chief Sustainability Officer
Other C-level Executive
Corporate Secretary
Legal Counsel/General Counsel
Other
Please select the activities that are undertaken by these units/functions with significant responsibility for integrity in your company? (please check all that apply)
Developing and maintaining internal guidelines or codes
Overseeing implementation of those internal guidelines or codes
Reviewing/evaluating internal controls and risk-management mechanisms
In-person training
Developing online training
Testing and evaluation
Maintaining and responding to a reporting hotline
Random screening
Ad hoc integrity advice
Internal investigations
Internal audits
Due diligence on third parties
Risk assessments
Reviewing Whistleblower or compliant-mechanism reports
Reporting
Communication with employees/board and senior management/investors/shareholders
Internal remedial/disciplinary action for violation of integrity policies
I don't know
Other [please specify]:
Does your company provide training specifically in integrity or anti-corruption? If such training is not provided to all employees, management and board members, please select “other” and specify who receives it.
Yes, all employees, management and board members receive anti-corruption and integrity training
No, no one receives anti-corruption and integrity training
I don’t know if anyone receives anti-corruption and integrity training
Other
Strategic arrangements and approaches
If your company has developed explicit integrity and/or anti-corruption strategies, objectives or indicators, please provide a link or brief details about what those goals, strategies or indicators entail.
*Please estimate the percentage of operational budget that is currently allocated to preventing, detecting and addressing corruption and irregular practices in your company? (Please do not include calculations of cost estimates relating to compliance with enforcement actions or sanctions that have been paid. Please provide number in % form.)
*How would you characterise the allocation of operational budget to preventing, detecting and addressing integrity and anti-corruption?
As an asset/investment
As a cost/expense
I have no view
Other
What were the main motivations behind the current/existing approaches to integrity and anti-corruption in your company? (please select only the factors that had a significant influence on current approaches) (please check all that apply)
Self-driven, voluntary adoption of integrity and anti-corruption measures
Compliance with requirements imposed or requested / regulatory requirements
Change in corporate management
Following a public/media campaign
Following a union movement
Following a corruption scandal
Risk of personal liability of CEO or senior management
Risk of reputational damage
Risk of legal or enforcement action, or divestment by investors
Risk of legal or enforcement action by shareholders
Risk of debarment or exclusion to processes
Risk of potential corrupt acts or irregular practices
Risk of loss of earnings
Internal control, risk management and compliance
Please select the following integrity-related findings/recommendations/assessments that are brought to the attention of your company’s leadership (board and senior management)? If the item does not exist in your company, please select “does not exist”.
Findings of risk assessments that point to integrity or corruption risks
Internal audit findings/recommendations
External audit findings/recommendations
Recommendations from integrity functions
Reports or claims of irregular practices or corruption made through reporting channels
Evaluations of the board
Evaluations of senior management (c-suite)
Evaluations of internal controls (that may be separate from internal audits)
Other inputs, please specify
*Under which category of risks does your company categorise integrity or anti-corruption risks, if at all?
Strategic risk factors
Operational risk factors
Financial risk factors
Compliance risk factors
Separately (please specify)
Such risks are not explicitly treated
Other, please specify:
How often does your company generally conduct risk assessments aimed specifically at identifying, analysing and prioritising corruption risks?
Never
Annually
Every two to three years
Every 4-5 years
More than 5 years
I don’t know
*Which additional risk management mechanisms or tools/instruments does your company use, if any, for protecting your company’s integrity when operating with third parties, or in high-risk sectors (i.e. mining or extractive, construction) or activities (i.e. public procurement)? (e.g. ex ante risk assessment of proposals/third parties, collective action agreements, anti-corruption agreements or integrity pacts, certifying business coalitions, and collective engagement with governments or others (including civil society)).
Accountability
Liability regime
What is the liability regime of your company for corruption or irregular practices?
Your company as an entity is not liable at all
Your company as an entity is liable only when senior management (in the "directing mind" and will of the company) committed the crime (sometimes known as the identification doctrine or theory)
Your company as an entity is liable for wrongdoing by all officers, directors/board members, employees or agents acting within their employment and for the benefit of the company (sometimes known as vicarious or strict liability)
Your company as an entity is liable for failure to prevent wrongdoing, but allows for a defence of the company to demonstrate that it had adequate compliance or related procedures in place to prevent misconduct (sometimes known as partial or adjusted strict liability)
Other [please specify]:
Please list any company positions (e.g. board members, CFO, CEO) that are exempt from the application of your company’s liability regime?
Internal and external audit
*Please best describe your company’s internal audit unit/function:
Required, in line with government departments/agencies
Required, in line with listed companies
Required, in line with other privately incorporated companies
Voluntarily established
Not applicable/do not have internal audit
Other
(Ask only if NOT said “yes” to IA as IF) To whom does the internal audit function/unit report? (please select all that apply)
Board
Audit committee (if existing)
Senior management
Other [please specify]:
Which types of internal audits are undertaken in your company? Select all that apply.
Performance audits (efficiency, effectiveness and economy of operations)
Compliance audits (compliance with legal norms and standards)
Financial audits (audit of financial reports and reporting processes)
Other audits (please specify)
Transparency
Does your company publicly disclose/report the following material financial and non-financial information on the enterprise? (if none of the above, please specify what other material financial or non-financial information is disclosed). (please select all that apply)
A clear statement to the public of enterprise objectives and their fulfilment
Enterprise financial and operating results
The governance, ownership and voting structure of the enterprise
The remuneration of board members and key executives;
Board member qualifications and selection process
Any board evaluations
Any material foreseeable risk factors and measures taken to manage such risks;
Any financial assistance, including guarantees, received from the state and commitments made on behalf of your company
Any material transactions with the state and other related entities;
Other, please specify
Through which sources/documentation does your company report on its integrity policies or anti-corruption efforts? (please select all that apply)
Annual Report
Compliance Report
CSR/Sustainability Report
Information published on organisation website
Internal documents only
Information is not reported
I don't know
Other [please specify]:
Self-reporting and whistleblowing mechanisms
Which mechanisms are made available to internal and/or external persons to report suspected instances of corruption or irregular practices involving your company? (please select all that apply)
Online (internal site)
Online (external site)
Telephone (internal hotline)
Telephone (external hotline)
Formalised whistleblowing mechanism
In person, ombudsman
In person, other
Other [please specify]:
*Please estimate how many reports/claims have been made through these channels in the last year, and how many pertain to corruption and irregular practices? (please respond in numeric characters)
How are internal and external reports/claims about corruption or irregular practices categorised/classified when coming through your company’s reporting mechanism?
Anonymously
Confidentially
Attributed to the individuals who made them when discussed within the organisation
I don't know
Other [please specify]:
To whom are reports and claims channelled to / who receives them? (please select all that apply)
External service provider
Board
Board committee
CEO
Chief Audit Executive
Chief Compliance Officer
Chief Financial Officer
Chief Sustainability Officer
General Counsel
External counsel (i.e. private legal practitioner)
Human Resources Department
Union Representative
Other [please specify]:
Does your company have legal protection from discriminatory or disciplinary action for those who disclose wrongdoing in good faith, to competent authorities, on reasonable grounds?
Yes, required by law
Yes, voluntary
No
I don’t know
(If yes) Please describe how this written policy is effectively guaranteed (e.g. retaliation as grounds for discipline up to and including dismissal?)
Specific company integrity and anti-corruption risks
In your opinion, to what degree does each factor pose as an obstacle to effectively promoting integrity and preventing corruption in, or involving, your company? (please respond in view of your specific company’s existing/true risks and its operations, not hypothetical. If the below factors are not present or do not exist in your company, please select “not applicable/does not exist". If they exist, but do not pose an obstacle, please select "not at all an obstacle".)
Matrix question:
