Good Governance for Medicines
|
|
- Ursula Lindsey
- 6 years ago
- Views:
Transcription
1 Good Governance for Medicines A Framework for Good Governance in the Pharmaceutical Sector Good Governance Good Health What is Good Governance? Good governance is an essential factor for sustainable development and economic growth at all levels and within all sectors of society. There are many different definitions of governance and good governance, still there is an emerging general consensus that governance is about managing the resources and affairs of society to promote the well-being of its members. The term good governance is increasingly used to emphasize the need for governance to operate with due regard for the rule of law and especially in a manner free of corruption. Good governance is participatory, consensus oriented, accountable, transparent, responsive, effective and efficient, equitable and inclusive, and follows the rule of law. A framework for good governance in the pharmaceutical sector WHO Model Framework Definition of Good Governance in the WHO GGM programme In the WHO Good Governance for Medicines (GGM) programme, good governance refers to the formulation and implementation of appropriate policies and procedures that ensure the effective, efficient and ethical management of pharmaceutical systems, in particular medicine regulatory systems and medicine supply systems, in a manner that is transparent, accountable, follows the rule of law and minimizes corruption. Objectives of the WHO GGM Programme The GGM programme focuses on the fundamental need to have laws, regulations, policies and procedures in place to improve management of pharmaceutical systems and create a corrupt-free environment to promote access to good quality medicines. Its primary emphasis is on prevention of future corruption and on improving systems. This leaflet summarizes a policy document, A framework for good governance in the public pharmaceutical sector. It presents a model to help countries draw up their own national framework for promoting good governance, and relates to Phase II of the three-step GGM programme. > Clearance Ministry of Health PHASE I National transparency assessment > PHASE II Development national GGM framework Figure 1 Phases of the GGM programme > PHASE III Implementation national GGM programme Assessment report GGM officially adopted GGM national strategy
2 Components of a National Framework for GGM The term framework in this document refers to the basic components needed in the GGM programme to address and prevent corruption in the pharmaceutical sector. The framework proposed here integrates two basic strategies necessary to promote good governance and to reduce corrupt practices: The two basic strategies needed to address corruption Values-based strategy: increasing institutional integrity by promoting moral values and ethical principles as a way of motivating public servants to behave ethically (bottom-up by nature) Discipline-based strategy: establishing laws, regulation and administrative procedures for combating corruption and for the management of the pharmaceutical sector, with appropriate punitive consequences for violations (top-down by nature) Participation of key actors and stakeholders in a consultative process will be vital in the review and analysis of the following 10 components of the proposed GGM framework. 1. Framework of Moral Values and Ethical Principles National integrity is a basic prerequisite for the performance of good governance, ensuring ethical practice in the implementation of policies. The WHO model framework for GGM is based on the following moral values: Justice/Fairness - Justice relates to the exercise of impartial judgement in determining the truth of facts and principles in collective decision-making. Fairness refers to justice and personal moral responsibility for the individual. Truth - This is the basis for trust, integrity and honour - for both the individual and society. Service to the Common Good - A public servant should fulfil the moral imperative to use his/her official position to serve the public interest. Trusteeship - A public institution cannot be effective without an adequate degree of public trust, which is only granted to public servants and organizations that demonstrate trustworthiness. 2. Code of Conduct Studies by Transparency International indicate that countries with an established framework for good governance based on a code of conduct, ethical principles and other key components of an integrity system report the lowest levels of corruption. There is a logical and consistent link between values, principles and a code of conduct. The code of conduct attempts to articulate in concrete terms the application of ethical principles, describing the expected behaviour of a public servant. A public servant who adheres to a code of conduct would avoid situations of conflicts of interest or other unethical practices that lead to corruption. 3. The Socialization of Moral Values, Ethical Principles and Code of Conduct This refers to the process where these elements can be learned, internalized, applied and promoted by key actors within the pharmaceutical sector of health ministries, until they become fully integrated into the institutional culture. Some key elements of the socialization process include: 2
3 Consciousness-raising activities targeting key actors about the importance of the issue of corruption and the need to address it. Activities can include information sharing and facilitation of critical-thinking exercises. Transforming dysfunctional mental models assuming that corruption is inevitable and sustaining patterns of unethical practices and an institutional culture that tolerates corruption. Activities can include raising awareness of specific dysfunctional models and facilitating critical-thinking exercises. Development of intrinsic motivation to apply moral values, ethical principles and to observe a code of conduct. Activities can include conferences, workshops, pamphlets explaining the GGM framework and code of conduct, newspaper articles, institutional bulletins, educational videos and posters. BOTTOM-UP 4. Promotion of moral leadership 5. Enforcement of existing anti-corruption legislation 6. Whistle-blowing mechanisms 7. Sanctions on reprehensible acts 8. Improving pharmaceutical management systems TOP-DOWN # # 1. Framework of moral values & ethical principles Justice/fairness Truth Service to common good Trusteeship 2. Code of conduct 3. Programme for socialization of Valuesbased ethical framework and code of conduct Disciplinebased 9. Collaboration between anti-corruption agencies, CSOs and private sector 10. Management, coordination and evaluation of GGM programme (Steering Committee & Task Force) Figure 2 Components of a national GGM framework 4. Moral Leadership Training Highly committed, moral leadership is essential for the effective functioning of an integrity system and the application of a framework for good governance at every level. In the current anti-corruption discourse the vital importance of leadership in promoting reform is increasingly mentioned, with different terms such as "ethical leadership", "values-based leadership" or "principled-based leadership". The underlying concepts behind these terms have a common ground emphasizing the importance of the moral dimension of leadership which is needed for promoting good governance and for fighting corruption. 5. Enforcement of Existing Anti-Corruption Legislation The GGM Programme draws on existing national anti-corruption legislation for support of the integrity system and the implementation of administrative and technical measures. It makes the best use of anti-corruption legisation for the implementation of the GGM programme. 3
4 6. Whistle-blowing Mechanisms Most cases of responsible whistle-blowing are courageous acts performed by public servants who place public interest above personal self-interest. A mechanism to protect the whistle-blower from retaliation or victimization is required which would also protect public servants from harmful false allegations. 7. Sanctions on Reprehensible Acts The control of reprehensible acts requires policies and procedures regarding the gradation of measures that will be applied in dealing with acts of corruption. These can be grouped: Internal sanctions implemented by the institution External legal sanctions implemented by the legal system and law enforcement. Decisions regarding the type of sanctions to be applied depend on the nature and gravity of the act. In general, serious acts of corruption should be dealt with using external measures. The various Conventions that support the anti-corruption movement criminalize acts of corruption and propose legal sanctions. Existing legal and administrative sanctions should be reviewed to ensure that they provide adequate deterrence - making corruption a high risk and low profit undertaking. 8. Improving Pharmaceutical Management Systems Phase I of the GGM programme consists of a national assessment measuring the transparency of key functions of national pharmaceutical systems. These assessments in reality identify the loopholes in the country, making the regulation and supply systems vulnerable to corrupt practices. The transparency assessment report is then formally presented to the Ministry of Health for review, creating a positive input for discussion. Administrative and technical recommendations are also presented for assessment, approval and implementation. Internal and external auditing of financial management should be in accordance with standards established by government legislation and good auditing procedures. 9. Inter-institutional Collaboration in Anti-corruption Movement The national GGM programme cannot succeed in achieving its objectives without effective coordination of efforts with other agencies promoting good governance and/ or working on issues of corruption. Civil society organizations, such as Transparency International, Procurement Watch, Oxfam UK and others, have provided valuable institutional moral leadership in the anti-corruption movement. Civil society organizations should be encouraged and supported in all these vital areas. An independent free press and other forms of media will raise public awareness of corruption and inform on progress in enforcing anti-corruption Conventions. 10. Management and Evaluation of the GGM Programme The effective coordination, management, and evaluation of a national GGM programme within a Ministry of Health will require a trained human resources team and adequate logistical support. If a MoH does not have an integrity system in place, then the GGM programme task force should be given the authority and support to carry out those activities that have direct bearing on the GGM programme. Capacity should be developed in response to needs of other MoH departments. 4
5 Climate of Corruption Corruption is the abuse of entrusted power for private gain. Transparency International Corruption impacts on: Health: Waste of public resources reduces government's capacity to provide good quality essential medicines. Unsafe medical products begin to proliferate on the market. Economy: With pharmaceutical expenditure in low-income countries estimated at 25-65% of total health-care spending, corruption represents a major financial loss. Image/Trust: Inefficiency and lack of transparency reduces credibility in public institutions and erodes the trust of the public and donors. Globally more than US$ 4.1 trillion is spent on health services each year and the value of the international pharmaceutical market is estimated at US$ 600 billion. Such large amounts of money are an attractive target for abuse, corruption and unethical practices. For example, Transparency International estimates that 10 to 25% of all public procurement spending is fraudulently siphoned off, and in some countries up to two-thirds of scarce medicine supplies in hospitals are lost to theft and corruption. Corruption in the pharmaceutical sector can take many forms and can happen at any step of the medicines chain. Conflicts of interest are often the motivating force generating unethical behaviour. When a government official or an expert serving on a government committee has a conflict of interest, s/he may put undue pressure and influence on the final decision to favour a particular company, instead of basing the decision on scientific evidence. Bribery and gift giving can be proactively offered or extorted by public servants. For example, suppliers can offer government officials a bribe to register medicines without the required information or to leave out findings on medicines quality in inspection reports. Or else, government officials may slow down registration procedures in order to pressurize suppliers into paying a bribe. Other forms of corruption or unethical practices include theft in the distribution chain for personal use or diversion for private sector resale, collusion in bid rigging during procurement by providing vendors with confidential and privileged information. Favouritism is also common, with officials favouring recruitment and/or promotion of family members (nepotism) or friends (cronyism) instead of basing their decision on professional merit. Development agencies increasingly recognize corruption as the single greatest obstacle to social and economic development, creating an entrenched vicious cycle: bad governance produces corruption and corruption destroys the basis of good governance. Petty and grand corruption feed on each other and both must be addressed and eliminated Petty corruption refers to small-scale corruption practiced by lower-level public servants who may extort bribes for their services and justify their corrupt behaviour as a survival mechanism to compensate for low salaries. This type of corruption can have an upward spiral effect when supervisors and higher-level officials demand a share of the bribes. Petty corruption has a profound debilitating effect on the integrity system of a nation and its existence is often the sign indicting the existence of grand corruption practices by high-level public servants. Grand corruption is large scale and often involves large international bribes and hidden overseas bank accounts. Exporting nations may knowingly, or unknowingly, offer tax breaks for bribes paid and refuse to regard trans-border corruption of public officials as criminal behaviour. This type of corruption seems to be motivated more by greed then need. 5
6 Constructing a Frame: objective of GGM programme Phase II Construction of a national framework for Good Governance in the public pharmaceutical sector requires consensus building through a consultation process about which components should be included. It also requires the participation of key actors and stakeholders in the following processes: Review and analysis of the moral values, ethical principles and code of conduct proposed in this document, as a reference point for consideration and consultation; Construction of a national framework designed to improve governance and management in the pharmaceutical sector. Existing legislation and other relevant documents should be considered as reference points in this process; Official adoption and promotion of the national GGM framework by the Ministry of Health. The basic need for consensus building makes it advisable to circulate a copy of the established framework for review and revision periodically. This would assure genuine participation and would motivate renewed commitment to applying the framework in the performance of public duties. Conclusion Corruption in the public pharmaceutical sector is endangering the health of millions of people worldwide. There is no easy and quick solution, with entrenched unethical practices found throughout the interrelated stages of the medicine chain. The ongoing success of a national GGM programme will depend on the collaboration of the public sector, civil society and the private sector to identify, address and prevent corruption. By promoting a corruption-free environment and access to good quality medicines, the Good Governance for Medicines programme is saving lives and improving global health-care provisions. It is also setting a preventive agenda for the future - a future where corruption has nowhere to hide. Key GGM documents: Measuring Transparency in the Public Pharmaceutical Sector: Assessment Instrument. Geneva, World Health Organization. (Working document). Anello E. A Framework for Good Governance in the Pharmaceutical Sector. Geneva, World Health Organization. (In preparation). Good Governance for Medicines: Curbing Corruption in Medicines Regulation and Supply. Geneva, World Health Organization, Good Governance for Medicines: Assessment Instrument. Geneva, World Health Organization, Good Governance for Medicines Programme Progress Report, February Geneva, World Health Organization, Additional information and key documents: Or ggminfo@who.int Department of Essential Medicines and Pharmaceutical Policies, WHO, Geneva All reasonable precautions have been taken by the World Health Organization to verify the information contained in this publication. However, the published material is being distributed without warranty of any kind, either expressed or implied. The responsibility for the interpretation and use of the material lies with the reader. In no event shall the World Health Organization be liable for damages arising from its use. This document has been produced with the financial assistance of the European Union. The views expressed herein are those of the authors and can therefore in no way be taken to reflect the official opinion of the European Union. WHO/EMP/MAR/ World Health Organization 2009
Good Governance for Medicines Programme Progress Report
Good Governance for Medicines Programme Progress Report February 2009 Corruption is the single greatest obstacle to social and economic development in countries worldwide, undermining democracy and creating
More informationEvaluation of the Good Governance for Medicines programme ( ) Brief summary of findings
Evaluation of the Good Governance for Medicines programme (2004 2012) Brief summary of findings Evaluation of the Good Governance for Medicines programme (2004 2012): Brief summary of findings i This report
More informationWHO Good Governance for Medicines programme - Zambia
WHO Good Governance for Medicines programme - Zambia 13 th ICDRA Meeting Ms Esnat Mwape Director General Berne, Switzerland 19 th September, 2008 Pharmaceutical Regulatory Authority, Zambia Presentation
More informationAnti-Corruption Policy
Anti-Corruption Policy I. Policy Statement The EQMM Anti- Corruption Policy is a living document that reinforces EQMM human rights based principles and values. This document is a work in progress, bearing
More informationJordan Framework For Good Governance in the Pharmaceutical Sector
Jordan Framework For Good Governance in the Pharmaceutical Sector 1 Acknowledgement The Steering Committee and Task Force members of the Good Governance in Medicine Programme in Jordan would like to acknowledge
More informationNATIONAL ANTI-CORRUPTION STRATEGY POLICY PAPER
NATIONAL ANTI-CORRUPTION STRATEGY POLICY PAPER 1.0 INTRODUCTION 1.1 The Government of Liberia recognizes that corruption has contributed substantially to the poor living standards of the majority of the
More informationANTI-FRAUD AND CORRUPTION POLICY. For the ACT Alliance
ANTI-FRAUD AND CORRUPTION POLICY For the ACT Alliance Approved by ACT International Executive Committee on April 27 th, 2009 This document was updated in March 2010 to take in account the change of name
More informationRecommendation of the Council for Development Co-operation Actors on Managing the Risk of Corruption
Recommendation of the Council for Development Co-operation Actors on Managing the Risk of Corruption 2016 Please cite this publication as: OECD (2016), 2016 OECD Recommendation of the Council for Development
More informationANTI- CORRUPTION POLICY
ANTI- CORRUPTION POLICY CHAPTER 1 INTRODUCTION ZERO TOLERANCE TOWARDS CORRUPTION The anti-corruption policy provides guidance for how Institute employees must react when faced with corruption and corrupt
More informationGood Governance in the Pharmaceutical Sector. Deirdre Dimancesco Department of Essential Medicines and Health Technologies
Good Governance in the Pharmaceutical Sector Deirdre Dimancesco Department of Essential Medicines and Health Technologies What is governance? Process of decision-making and implementation Manner how power
More informationAnti-Bribery and Corruption Policy
Anti-Bribery and Corruption Policy Policy # BW-GRP- ABC-01 Effective Date 30 September 2017 Email hilaryw@barloworld.com Version V2.2 Contact Hilary Wilton Phone 011 445 1168 Purpose... 1 Scope... 1 Regulatory
More information6 TH ASIA PACIFIC PHARMACEUTICAL AND MEDICAL DEVICE COMPLIANCE CONGRESS 21 SEPTEMBER 2016
6 TH ASIA PACIFIC PHARMACEUTICAL AND MEDICAL DEVICE COMPLIANCE CONGRESS 21 SEPTEMBER 2016 Sophie Peresson Director, Pharmaceuticals & Healthcare Programme - Transparency International UK CPI 2015 TI s
More informationWhat is corruption? Corruption is the abuse of power for private gain (TI).
Outline presentation What is corruption? Corruption in the water sector Costs and impacts of corruption Corruption and human rights Drivers and incentives of corruption What is corruption? Corruption is
More informationMINISTRY OF FISHERIES Anti Corruption Policy
MINISTRY OF FISHERIES Anti Corruption Policy 1.0 Introduction The Ministry of Fisheries attaches great value to its reputation. The Ministry of Fisheries recognises that the risk of corruption is present
More informationKEI INDUSTRIES LIMITED
Wires and Cables KEI INDUSTRIES LIMITED VIGIL MECHANISM/ WHISTLE BLOWER POLICY (Amended w.e.f. November 6, 2014) 1. PREFACE KEI Industries Limited ( the Company ) is committed to adhere to the highest
More informationREGIONAL CONFERENCE ON PROMOTING INTEGRITY IN CUSTOMS AND IN BORDER SERVICES IN CENTRAL ASIA AND SOUTH CAUCASUS
REGIONAL CONFERENCE ON PROMOTING INTEGRITY IN CUSTOMS AND IN BORDER SERVICES IN CENTRAL ASIA AND SOUTH CAUCASUS Almaty Kazakhstan, 12-13 13 July 2010 WHAT IS INTEGRITY? A A positive set of attitudes which
More informationPremise. The social mission and objectives
Premise The Code of Ethics is a charter of moral rights and duties that defines the ethical and social responsibility of all those who maintain relationships with Coopsalute. This document clearly explains
More informationRoche. Working with Government Officials: Good Practice Guidelines
Roche Working with Government Officials: Good Practice Guidelines 1 Roche s Position, Commitment and Expectation Government bodies and elected officials (hereafter called Government Officials 1 ) play
More informationNORTHERN IRELAND PRACTICE AND EDUCATION COUNCIL FOR NURSING AND MIDWIFERY
NIPEC/12/12 NORTHERN IRELAND PRACTICE AND EDUCATION COUNCIL FOR NURSING AND MIDWIFERY Anti-Bribery Policy May 2012 Review date: April 2015 Centre House 79 Chichester Street BELFAST BT1 4JE Tel: (028) 9023
More informationPHARMAC s implementation of Trans-Pacific Partnership (TPP) provisions and other amendments to application processes September 2016 Appendix two
Appendix 2: Annex 26-A (Transparency and Procedural Fairness for Pharmaceutical Products and Medical Devices) to Chapter 26 (Transparency and Anti-Corruption) of the Trans-Pacific Partnership Agreement.
More informationVIGIL MECHANISM (WHISTLE BLOWER POLICY) OF STAR AGRIWAREHOUSING AND COLLATERAL MANAGEMENT LIMITED
VIGIL MECHANISM (WHISTLE BLOWER POLICY) OF STAR AGRIWAREHOUSING AND COLLATERAL MANAGEMENT LIMITED 1 VIGIL MECHANISM (WHISTLE BLOWER POLICY) 1. Preface The Company has adopted the Code of Ethics & Business
More informationFirstRand Suppliers Code of Conduct
FirstRand Suppliers Code of Conduct - 2 - table of contents 1. WHY DOES FIRSTRAND HAVE A SUPPLIERS CODE OF CONDUCT POLICY? 3 2. POLICY SCOPE 3 2.1 Who does the policy apply to? 3 2.2 Who is a supplier
More informationTo: All contacts in England, Wales, Scotland and Northern Ireland
Briefing 11/32 July 2011 Bribery Act 2010 To: All contacts in England, Wales, Scotland and Northern Ireland Key issues New offences created to replace previous bribery crimes Both the private and public
More informationIMC Worldwide Ltd. Business Ethics Policy
IMC Worldwide Ltd. Business Ethics Policy Business integrity is the quality of being honest and having strong moral principles. A business that holds itself to consistent moral and ethical standards earns
More informationAnti-Bribery and Corruption Policy
Anti-Bribery and Corruption Policy 1. Policy Statement In accordance with the highest standards of professional practice and good governance, the University does not tolerate bribery or corruption of any
More information1.3 The required standards of integrity confer a level of personal responsibility upon individuals. This Policy thus applies to:
ANTI-BRIBERY POLICY 1. Introduction 1.1 The University has an absolute commitment to acting ethically, lawfully and with integrity in all its dealings, wherever it operates in the world. As part of this
More informationNETCARE LIMITED CORPORATE GOVERNANCE ANTI-CORRUPTION POLICY POLICY NUMBER COR12 CORPORATE GOVERNANCE PREPARED BY PREPARATION DATE JUNE 2014
NETCARE LIMITED CORPORATE GOVERNANCE POLICY POLICY NUMBER COR12 PREPARED BY APPROVED BY CORPORATE GOVERNANCE CORPORATE GOVERNANCE PREPARATION DATE JUNE 2014 ISSUE DATE FEBRUARY 2017 REVISION DATE FEBRUARY
More informationNATIONAL STRATEGY FOR PREVENTING AND COMBATING CORRUPTION TOWARDS 2020
THE GOVERNMENT SOCIALIST REPUBLIC OF VIETNAM Independence Freedom Happiness Hanoi, date..month.2008 DRAFT 7 September 2008 NATIONAL STRATEGY FOR PREVENTING AND COMBATING CORRUPTION TOWARDS 2020 (Promulgated
More informationKey elements to be considered for the Inter-American Convention against Corruption review methodology
www.tilac.org www.transparency.org Key elements to be considered for the Inter-American Convention against Corruption review methodology 8 April 2002 Transparency International and its chapters throughout
More informationNORTHERN IRELAND SOCIAL CARE COUNCIL
NORTHERN IRELAND SOCIAL CARE COUNCIL BRIBERY POLICY FINAL SEPTMBER 2012 1. INTRODUCTION The Bribery Act 2010 (the Act) introduces a new, clearer regime for tackling bribery that applies to all commercial
More informationDirector of Customer Care & Performance. 26 April The Board is asked to consider and approve the attached draft
To: From: Subject: Status: Date of Meeting: BSO Board Director of Customer Care & Performance Anti Bribery Policy For Approval 26 April 2012 The Board is asked to consider and approve the attached draft
More informationThis policy and Code of Conduct will form part of the induction of new EMPLOYEES (as defined below).
ANTI CORRUPTION POLICY STATEMENT OF COMMITMENT RICHLAND GROUP (as defined below) is fully committed to conduct our business with utmost integrity and with the highest ethical standards, and in compliance
More informationExecutive summary. Transparency International
Executive summary Transparency International Every year, the world spends more than US $3 trillion on health services, most of which is financed by taxpayers. These large flows of funds are an attractive
More informationYMCA NSW Whistle Blower Policy
1. Document control Overview A whistle-blower is any employee, volunteer, contractor or people associated with the YMCA NSW that detects wrongdoing, or has reasonable grounds for suspecting wrongdoing
More informationRWANDA ANTI- CORRUPTION POLICY
REPUBLIC OF RWANDA OFFICE OF THE OMBUDSMAN RWANDA ANTI- CORRUPTION POLICY Kigali, June 2012 0 TABLE OF CONTENTS EXECUTIVE SUMMARY... 2 1. Background to the Rwanda anti-corruption policy... 3 2. Status
More informationASTRAZENECA GLOBAL STANDARD EXPECTATIONS OF THIRD PARTIES
ASTRAZENECA GLOBAL STANDARD EXPECTATIONS OF THIRD PARTIES This Global Standard sets out AstraZeneca s ethical business expectations of Third Parties with which it interacts to ensure their conduct is consistent
More informationAnticorruption in the water sector
Anticorruption in the water sector Dr. Ir. Jeroen Vos Wageningen University, The Netherlands Corruption in the water sector Corruption is defined by the UNDP and Transparency International as abuse of
More informationAnti-Fraud, Bribery and Corruption Policy
Anti-Fraud, Bribery and Corruption Policy Anti-Fraud, Bribery and Corruption Policy Version 2 Approved by: Audit and Risk Committee Approved date: 22 May 2017 1.0 Introduction 1.1 Optivo is committed to
More informationANTI - CORRUPTION POLICY
Republic of Mauritius ANTI - CORRUPTION POLICY of the MINISTRY OF CIVIL SERVICE AND ADMINISTRATIVE REFORMS Our core values : Accountability Selflessness Impartiality Objectivity Integrity Openness Honesty
More informationWhistle Blower Policy. NIF PRIVATE LIMITED, (Part), Block P & T Fazal Ganj, Kalpi Road, Kanpur (U.P.)
Whistle Blower Policy NIF PRIVATE LIMITED, 119-121 (Part), Block P & T Fazal Ganj, Kalpi Road, Kanpur-208012 (U.P.) WHISTLE BLOWER POLICY 1. INTRODUCTION 1.1 NIF Private Limited (the Company ) believes
More informationUnoficial translation BASIC GUIDELINES NATIONAL STRATEGY FOR CORRUPTION PREVENTION AND COMBATING
Unoficial translation BASIC GUIDELINES NATIONAL STRATEGY FOR CORRUPTION PREVENTION AND COMBATING 2004 2008 2 CONTENTS 1. INTRODUCTION...3 2. CURRENT SITUATION...3 3. PROBLEMS IN PREVENTING AND COMBATING
More informationIndustry Agenda. PACI Principles for Countering Corruption
Industry Agenda PACI Principles for Countering Corruption January 2014 World Economic Forum 2014 - All rights reserved. No part of this publication may be reproduced or transmitted in any form or by any
More informationPreventing corruption in humanitarian aid - logistics
Preventing corruption in humanitarian aid - logistics Presentation at AIDF Asia Summit 2016 Conference 21 June 2016 Anne Signe Hørstad Transparency International Norway Cpi 2015: The top RANK COUNTRY/TERRITORY
More informationCombating Extortion and Bribery: ICC Rules of Conduct and Recommendations
International Chamber of Commerce The world business organization Commission on Anti-Corruption Combating Extortion and Bribery: ICC Rules of Conduct and Recommendations 2005 edition International Chamber
More informationCivil Society Statement for the Global Forum on Asset Recovery
Civil Society Statement for the Global Forum on Asset Recovery On the occasion of the first Global Forum on Asset Recovery co-hosted by the United States and the United Kingdom in Washington D.C., USA,
More information2. Good governance the concept
2. Good governance the concept In the last twenty years, the concepts of governance and good governance have become widely used in both the academic and donor communities. These two traditions have dissimilar
More information1. offering, promising or giving a bribe (in the UK or overseas); 2. requesting, agreeing to receive or accepting a bribe (in the UK or overseas);
BRIBERY ACT POLICY Explanation - Bribery Act Bribery can be defined as an inducement or reward offered, promised or provided in order to gain commercial, contractual, regulatory or personal advantage.
More informationUACN WHISTLEBLOWING POLICY
UACN WHISTLEBLOWING POLICY JULY 2015 VERSION 2.0 Document approval This document was approved by the Board of UAC of Nigeria PLC on 29 th July 2015 2 Table of Contents 1. Policy Statement..... 4 2. Application.....
More informationBoris Divjak Director of U4 Anti-Corruption Resource Centre (Bergen, Norway) Transparency International School on Integrity, Vilnius 07 July 2015
Petty Corruption Hitting hardest the poorest Boris Divjak Director of U4 Anti-Corruption Resource Centre (Bergen, Norway) Transparency International School on Integrity, Vilnius 07 July 2015 Corruption
More informationAnti Bribery and Corruption Policy. Regulatory Compliance Department. Compliance and Legal Management Group
Anti Bribery and Corruption Policy Regulatory Compliance Department Compliance and Legal Management Group 1 Index Page 1. Principle 3 2. Definition 3 3. Applicable Scope 3 4. Related or Responsible Person
More informationMonrovia Statement on Whistle-blower and Witness Protection in West Africa
Monrovia Statement on Whistle-blower and Witness Protection in West Africa Adopted in Monrovia, on 21 September 2016 From 19 to 21 September 2016, national stakeholders from 12 countries from West Africa
More information10 ANTI-CORRUPTION PRINCIPLES FOR STATE-OWNED ENTERPRISES. A multi-stakeholder initiative of Transparency International
10 ANTI-CORRUPTION PRINCIPLES FOR STATE-OWNED ENTERPRISES A multi-stakeholder initiative of Transparency International Transparency International is a global movement with one vision: a world in which
More informationSTEELCO GUJARAT LIMITED. Whistle Blower Policy
STEELCO GUJARAT LIMITED Whistle Blower Policy INDEX Sr.No. 1.0 Preamble 2.0 Definitions 3.0 Eligibility 4.0 Guiding Principles 5.0 Whistle Blower Role & Disqualification 6.0 Procedures Essentials and handling
More informationWhistle-Blowing Policy and Procedure Manual
Whistle-Blowing Policy and Procedure Manual TABLE OF CONTENTS 1. EXPLANATORY FORWARD 2 2. POLICY STATEMENT 3 3. OBJECTIVES OF THE POLICY 3 4. SCOPE OF THE POLICY 4 5. COMMITMENT TO THE POLICY 5 6. PROCEDURE
More informationFirstRand anti-bribery policy
FirstRand anti-bribery policy - 1 - table of contents 1. DEFINITIONS 3 2. POLICY CONTEXT 4 2.1 Ensuring integrity in all business dealings 4 2.2 What is bribery? 4 2.3 Purpose of the policy? 5 2.4 How
More informationCounter-fraud and anti-bribery policy
Counter-fraud and anti-bribery policy Responsible Officer Author Ben Bennett, Business Planning & Resources Director Corporate Office Date effective from May 2012 Date last amended November 2016 Review
More informationLESSON 14: Involving the private sector in the corruption prevention strategy
The United Nations Convention against Corruption Safeguarding against Corruption in Major Public Events LESSON 14: Involving the private sector in the corruption prevention strategy The private sector
More informationThis guidance applies to all members of the University including all employees and independent members of Council and its Committees.
UNIVERSITY OF ULSTER ANTI- BRIBERY GUIDANCE 1. Introduction This guidance applies to all members of the University including all employees and independent members of Council and its Committees. 2. Position
More informationWHISTLE BLOWER POLICY
WHISTLE BLOWER POLICY (The Board of Directors of Energy Efficiency Services Limited in their 34 th Board Meeting held on 20 th March, 2015 has adopted NTPC s whistle blower policy with suitable modifications)
More informationAIDENVIRONMENT ANTI-CORRUPTION AND BRIBERY POLICY
AIDENVIRONMENT ANTI-CORRUPTION AND BRIBERY POLICY CONTENTS CLAUSE 1. Policy statement... 3 2. Who is covered by the policy?... 4 3. What is bribery?... 4 4. Hospitality and gifts... 5 5. What is not acceptable?...
More informationIt is the responsibility of all Fletcher Personnel to understand and comply with this Policy, including any reporting requirements set out below.
POLICY: ANTI-BRIBERY AND CORRUPTION 1. POLICY STATEMENT AND PURPOSE Fletcher Building Limited ( Fletcher Building ) is committed to complying with the law in all jurisdictions in which we operate, as well
More informationThe Bribery Act Adequate procedures.
October 2010 The Bribery Act 2010. Adequate procedures. We set out in this note our suggestions as to the adequate procedures that a company may consider adopting as part of its process of updating compliance
More informationBeyond Passive Compliance: A Proactive Approach to Reducing Corruption
Remarks by Alan Boeckmann ECOA 2007 Annual Business Ethics & Compliance Conference Los Angeles September 26, 2007 Beyond Passive Compliance: A Proactive Approach to Reducing Corruption Thank you, Keith,
More informationPolicy Summary. Overview Why is the policy required? Awareness and legal compliance with Bribery Act is required to minimise risk to UHI and its staff
Policy Summary Overview Why is the policy required? Purpose What will it achieve? Scope Who does it apply too? Consultation/notification Highlight plans/dates Implementation and monitoring (including costs)
More informationFIA INSTITUTE ANTI BRIBERY AND CORRUPTION POLICY
! FIA INSTITUTE ANTI BRIBERY AND CORRUPTION POLICY 1. POLICY STATEMENT 1.1 As indicated in Article 8 of the Internal Regulations of the FIA Institute, we take a zero tolerance approach to bribery and corruption
More informationAnti-Bribery Policy WHC reserves the right to amend this policy at its discretion. The most up-to-date version can be downloaded from our website.
ANTI-BRIBERY POLICY ELT manager Director of Finance Responsible officer Director of Finance Date first approved by BoM 29 th March 2012 Date review approved by BoM 4 th October 2017 Next Review Date October
More informationCCG CO06: Anti-Fraud, Bribery and Corruption Policy
Corporate CCG CO06: Anti-Fraud, Bribery and Corruption Policy Version Number Date Issued Review Date V2 17/03/2016 01/09/2016 Prepared By: Consultation Process: Formally Approved: Policy Adopted From:
More informationPOLICY AGAINST BRIBERY AND CORRUPTION. Introductory Guidance. This policy has been introduced in response to the Bribery Act 2010 ( the Act )
POLICY AGAINST BRIBERY AND CORRUPTION Introductory Guidance This policy has been introduced in response to the Bribery Act 2010 ( the Act ) The Act creates four key offences:- Active bribery (the offence
More information17 TH ANNUAL PHARMACEUTICAL AND MEDICAL DEVICE COMPLIANCE CONGRESS 19 OCTOBER 2016
17 TH ANNUAL PHARMACEUTICAL AND MEDICAL DEVICE COMPLIANCE CONGRESS 19 OCTOBER 2016 Sophie Peresson Director, Pharmaceuticals & Healthcare Programme - Transparency International TRANSPARENCY INTERNATIONAL
More informationOn the Frontline against Corruption
KENYA ANTI-CORRUPTION COMMISSION On the Frontline against Corruption A Publication of Kenya Anti-Corruption Commission Department of Education Directorate of Preventive Services 1 About the Commission
More informationCorruption and sustainable development
Corruption and sustainable development Corruption poses a significant threat to countries around the world; it undermines democratic institutions, contributes to governmental instability and erodes trust.
More informationANTI-CORRUPTION POLICY. Adopted on June 12, 2012 by the boards of directors
ANTI-CORRUPTION POLICY Adopted on June 12, 2012 by the boards of directors 1. DEFINITIONS 1.1. By corruption, LWBC understands all the ways of using resources and skills that are contrary to the laws,
More informationBANK OF INDUSTRY LIMITED. Whistle blowing Policy
BANK OF INDUSTRY LIMITED Whistle blowing Policy SECTION 1: INTRODUCTION Whistle blowing vary in terms of definition, depending on the role it is designed to play in the society at large and the organization
More informationAchieving Corporate Integrity
Achieving Corporate Integrity Dr Mark Lovatt Transparency International Malaysia ti-malaysia@transparency.org.my www.transparency.org.my Integrity Unsinkable Titanic s current state How is integrity compromised?
More informationThe LTE Group. Anti-Bribery Policy Produced by. The LTE Group. LTEG anti-bribery policy v4 06/2016
The LTE Group Produced by The LTE Group LTEG anti-bribery policy v4 06/2016 All rights reserved; no part of this publication may be photocopied, recorded or otherwise reproduced, stored in a retrieval
More informationProper Business Practices and Ethics Policy
Proper Business Practices and Ethics Policy Synopsis 1. Crown Castle International Corp. ( Crown Castle ) and its affiliates 1 strive to conduct their business with honesty and integrity and in accordance
More informationI. STATEMENT OF COMMITMENT AGAINST CORRUPTION, BRIBERY & EXTORTION
CITY DEVELOPMENTS LIMITED ANTI-CORRUPTION POLICY & GUIDELINES* (*All employees of CDL are required to read the full version of the CDL Anti-Corruption Policy & Guidelines, which is available on CDL s intranet,
More informationICAO VENDOR SANCTION POLICY. Approved by the Council and published by its decision
ICAO VENDOR SANCTION POLICY Approved by the Council and published by its decision 23 March 2017 Table of Contents 1. BACKGROUND... 3 2. PURPOSE AND OBJECTIVE... 3 3. DEFINITIONS... 3 4. THE SANCTIONS BOARD...
More information2010 UK Bribery Act. A Briefing for NGOs
2010 UK Bribery Act A Briefing for NGOs June 2010 2010 UK Bribery Act A Briefing for NGOs 1. Introduction On April 8 th 2010, a new Bribery Act received Royal Assent one of the last bills to pass into
More informationNOBLE MOBILITY CHARTER OF CORPORATE SOCIAL RESPONSIBILITY
NOBLECARE NOBLE MOBILITY CHARTER OF CORPORATE SOCIAL RESPONSIBILITY WHO WE ARE NOBLE MOBILITY is a leading provider of moving and relocation services in the corporate market. The company s core values;
More informationANTI-BRIBERY AND CORRUPTION POLICY
Table of Content 1. Purpose... 2 2. Scope... 2 3. Responsibility... 2 4. General principles... 3 a. What is Bribery?... 3 b. Bribery of Government Officials... 4 c. Commercial Bribery... 6 d. Preventing
More informationCOUNCIL POLICY BACKGROUND
Policy Title: Whistle-blower Policy Policy Number: CC026 Report Number: AC2007-26 Approved by: Council Effective Date: 2007 May 28 Business Unit: City Auditor s Office BACKGROUND The Corporation of The
More informationWHISTLEBLOWER POLICY
WHISTLEBLOWER POLICY 1 Policy Statement: Organization is committed to creating a culture of Right Doing that encourages high standards of ethics, integrity and objectivity in individual conduct. 2 Overview
More informationWHISTLE BLOWER POLICY
WHISTLE BLOWER POLICY 1.0 PREFACE UEM Group is committed to the highest standards of professionalism, honesty, integrity and ethical behaviour in the conduct of its business and operations. With this in
More informationANTI-CORRUPTION POLICY FOR INNOVATION NORWAY
ANTI-CORRUPTION POLICY FOR INNOVATION NORWAY Document name Legal authority Category Applies to the following business/staff areas Approved by Anti-corruption policy for Innovation Norway Ethical guidelines
More informationAnti-Bribery and Corruption Policy. Intouch Holdings Plc
Anti-Bribery and Corruption Policy Intouch Holdings Plc MESSAGE FROM THE CHAIRMAN OF THE BOARD AND THE CHIEF EXECUTIVE OFFICER To: All directors, members of management and employees of the Company We at
More informationNATIONAL ANTI-CORRUPTION STRATEGY
1 Annex 1 NATIONAL ANTI-CORRUPTION STRATEGY 2005-2007 SUMMARY.2 A. BACKGROUND... 3 2. PRINCIPLES... 4 B. PRIORITY AREAS AND OBJECTIVES... 5 PRIORITY AREA I: PREVENTION, TRANSPARENCY, EDUCATION... 6 Objective
More informationBATA INDIA LIMITED WHISTLE BLOWER POLICY
BATA INDIA LIMITED WHISTLE BLOWER POLICY BATA INDIA LIMITED WHISTLE BLOWER POLICY I. Preamble Bata India Limited ( the Company ) believes in fair conduct of its affairs and sets the highest standards in
More informationCracking down on corruption
Cracking down on corruption CAPI, Columbia University, 16 October2014 Adam Graycar Australian National University adam.graycar@anu.edu.au http://tric.anu.edu.au Impacts Hampers economic performance/ growth
More informationAnti-Fraud, Bribery and Corruption Response Policy. Telford and Wrekin Clinical Commissioning Group
Anti-Fraud, Bribery and Corruption Response Policy 2018 Telford and Wrekin Clinical Commissioning Group The Anti-Fraud, Bribery and Corruption Policy for Telford and Wrekin Clinical Commissioning Group
More informationThe Bribery Act Southampton Solent University Key Guidance (May 2017)
The Bribery Act 2010 Southampton Solent University Key Guidance (May 2017) Bribery is a criminal offence in the UK and in most countries in which the University operates and from which our students come.
More informationADANI POWER LIMITED VIGIL MECHANISM / WHISTLE BLOWER POLICY
ADANI POWER LIMITED VIGIL MECHANISM / WHISTLE BLOWER POLICY (Approved on 6 th August, 2014; Amended on 3 rd May, 2016, Amended on 11 th November, 2017) Page 1 of 8 1. PREFACE Adani Power Limited (herein
More informationAnti-Bribery Policy. Anti-Bribery. Policy. Working Together. January Borders College 15/2/ Working Together.
Anti-Bribery Working Together Policy January 2016 Borders College 15/2/2016 1 Working Together History of Changes Version Description of Change Authored by Date 1.1 New Policy approved at Audit Committee
More informationFRAMEWORK FOR MAINSTREAMING CORRUPTION PREVENTION IN PUBLIC INSTITUTIONS
FRAMEWORK FOR MAINSTREAMING CORRUPTION PREVENTION IN PUBLIC INSTITUTIONS Prepared by: The Directorate of Preventive Services NOVEMBER 2007 FRAMEWORK FOR MAINSTREAMING CORRUPTION PREVENTION IN PUBLIC INSTITUTIONS
More informationGlobal Health Private Limited. Whistleblower Policy (Vigil Mechanism)
Global Health Private Limited Whistleblower Policy (Vigil Mechanism) INDEX OF CONTENTS Sl. No. Index Page Nos. 1. PREFACE 3 2. POLICY APPLICABILITY 3 3. DEFINITIONS 3 4. POLICY COVERAGE 4 5. MANNER OF
More informationAMAN strategy (strategy 2020)
AMAN strategy 2017-2020 (strategy 2020) Introduction: At times of political transition and building states, corruption tends to spread due to lack of legislations and firmly established institutions in
More informationTRANSPARENCY INTERNATIONAL NEW ZEALAND
Institute of Directors 15 th August 2018, 7:30am Quality Hotel Plymouth International Taranaki TRANSPARENCY INTERNATIONAL NEW ZEALAND Suzanne Snively, ONZM Chair, Transparency International New Zealand
More informationThe water services crisis is essentially a crisis of governance
Water Governance: Applying Anti-Corruption in Water Capacity Building Workshop for Improving the Performance of Water Utilities in the African Region 6-8 December6, 2006 Nairobi, Kenya Dr. Håkan Tropp
More informationCartels, corruption and the importance of inter-agency cooperation in the fight against unfair practices in public procurement
KKV1000, v1.3, 2011-12-15 2014-10-01 1 (8) Cartels, corruption and the importance of inter-agency cooperation in the fight against unfair practices in public procurement Speech of Ms. Hanna Witt, Director
More informationANTI-BRIBERY & CORRUPTION POLICY
ANTI-BRIBERY & CORRUPTION POLICY 0 Anti-Bribery and Corruption Policy 1 Anti-Bribery and Corruption Policy Introduction This policy applies to Portmeirion Group PLC and its subsidiaries, (including Wax
More information