Fighting corruption together
Our global reputation as a trustworthy company is a key factor in our success. Compliance, integrity and anti-corruption are the core elements of our compliance management system. This includes a comprehensive system to identify and avoid risk. Staff rotation and the cross-checking principle play important roles here.
ANTI-CORRUPTION AT GIZ
Anti-corruption management is an important element of our compliance management system. We define corruption as the abuse or misuse for personal gain of the power conferred by public office or through private sector authorisations. This includes active and passive bribery, giving or accepting gifts or other services, employing or awarding contracts to closely connected or related persons and other conflicts of interest. Fraud and embezzlement are also crimes generally associated with corruption. Our Code of Conduct contains clear rules on how to deal with conflicts of interest and prevent corruption. All staff members undertake to uphold these principles with their employment contract.
For the projects and programmes that we implement on behalf of BMZ, the strategy paper Anti-Corruption and Integrity in German Development Policy serves as an additional binding frame of reference. Furthermore, we are a corporate member of Transparency International and regularly take part in its events. Contracts with service providers and consultants are subject to strict rules, with a view to minimising corruption risks.
SYSTEMATIC COMPLIANCE MANAGEMENT
To ensure compliance, integrity and anti-corruption, GIZ is continuing to expand its compliance management system. Founded in 2015, the Compliance and Integrity Unit is responsible for active coordination and management in conjunction with all relevant organisational units. The Integrity and Compliance Unit reports to the Management Board on compliance management measures every year and to the Supervisory Board every two years. Overarching integrity and compliance issues and basic policy decisions are addressed in a high-ranking Compliance Committee, which is made up of the Chair of the Management Board and several directors general of departments and directors of corporate units.
GIZ has a comprehensive risk identification system that systematically combines one-off data collection activities routine processes. The ongoing recording of compliance, integrity and corruption risks is integrated into the standard company-wide risk management process. By analysing and assessing existing and potential compliance risks, areas where action on compliance is needed are systematically identified and addressed as part of a risk-based compliance programme. The programme comprises measures for prevention, awareness-raising and response.
The GIZ country offices provide annual updates on the status of their measures to minimise compliance risks and fight corruption. As part of GIZ’s risk management system, every organisational unit within GIZ must also report on its risks – including compliance, integrity and corruption risks – and the measures it has taken to address these, every six months.
Our internal control system ensures proper commercial management of our projects. We regularly check whether financial and administrative operations within our projects are correct and efficient and whether we are in compliance with internal and external regulations. The focus is on procurement processes, proper accounting and HR management. GIZ’s internal systems are also monitored through a large number of external audits.
The correct use of financial resources is a top priority for GIZ. Procurement processes are therefore always carried out by at least two people from different organisational units. In addition, our staff rotation principle requires staff in positions with a high corruption risk to ‘rotate’ to a new post every six years at the latest. Any deviation from the staff rotation rule must be justified and documented.
Our IT systems ensure transparency as contracts are systematically recorded and evaluated for each contractor. We also document permit and publication requirements. This allows us to systematically report on all procurement processes around the globe.
EMBEDDED GLOBALLY IN ALL GIZ OFFICES
A systematic compliance management system was introduced for the entire field structure in 2018. In countries with a potentially increased compliance risk, core compliance teams organise and manage the compliance process. The respective country director is responsible for its success. The focus is on country-specific risks with respect to corruption and non-compliance. To minimise the risks identified on an ongoing basis, corresponding countermeasures are initiated and their effectiveness is assessed.
RAISING AWARENESS AND RECOGNISING VIOLATIONS
The Code of Conduct is also designed to support employees in recognising and avoiding conflicts of interest. New staff members are trained from the outset to recognise situations with a high corruption risk. Every new GIZ employee must complete the company’s online training on ethical conduct. Classroom-based training at mandatory onboarding events for new staff are also used to hone their awareness of possible conflicts of interest and corruption prevention.
Staff members, project partners, clients and the general public can contact our internal integrity advisors or an external ombudsperson confidentially to report any violations.
Our Code of Conduct contains clear rules on how to deal with conflicts of interests and prevent corruption: Code of Conduct.
A clear overview of global integrity management: Integrity management at GIZ.
Our Sustainability Programme 2016–2020 provides guidance and gives the Sustainability Office a management tool. It addresses the issue of integrity and compliance.