Working together to fight corruption
Anti-corruption at GIZ
At GIZ, we actively tackle corruption. Anti-corruption management is an important element of our compliance management system. Corruption is a broad term. We define corruption as the abuse or misuse, for personal gain, of the power or influence conferred by public office or through the private sector. This includes giving and accepting bribes and facilitating payments, embezzlement, nepotism, fraud or kick-back payments. Certain conflicts of interest can also constitute a form of corruption. Our Code of Ethics, which sets out GIZ’s key ethical principles, clearly bans all forms of corruption. And specific rules for dealing with conflicts of interest and avoiding corruption can be found in our Code of Conduct. All staff are obliged to comply with the Code of Ethics and the Code of Conduct.
For the projects that we implement on behalf of the German Federal Ministry for Economic Cooperation and Development (BMZ), we are guided by the strategy paper on ‘Anti-Corruption and Integrity in German Development Policy’. Contracts with service providers and consultants are subject to strict rules with a view to minimising corruption risks. We are also a corporate member of Transparency International. In signing the declaration of commitment, members undertake to uphold high ethical standards in business.
Systematic compliance management
To ensure compliance, integrity and anti-corruption, GIZ is expanding its compliance management system. It is coordinated and managed by the Compliance and Integrity Unit in collaboration with all the relevant organisational units. The Integrity and Compliance Unit reports to the Management Board on progress in compliance management every year and to the Supervisory Board every two years. A high-level Compliance Committee consisting of one managing director and several departmental directors general and directors of corporate units works to resolve overarching integrity and compliance issues and makes basic policy decisions.
The compliance management system (CMS) forms part of GIZ’s internal control system, which is designed to prevent risks, detect problematic issues at an early stage and respond appropriately to rule violations and unavoidable risks. As a result, GIZ has a comprehensive risk identification system. The continuous recording of compliance, integrity and corruption risks is integrated into the standard company-wide risk management process and also includes the field structure. In addition to individual risks, the countries at high risk also report on the overall picture with regards to compliance risks. By analysing and assessing existing and potential compliance risks, the need for action in this area is systematically identified and addressed as part of a risk-based compliance programme, with measures to prevent, investigate and respond to compliance issues.
Our internal control system and comprehensive rules also ensure proper commercial management of our projects. We regularly check whether the financial and administrative procedures within our projects are correct and efficient and whether we are in compliance with external and internal regulations. The focus is on procurement processes, accounting and HR management. GIZ’s projects and internal systems are also subjected to comprehensive 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 rotation principle requires that staff in functions with a high corruption risk must change roles at least every six years. Any deviation from the rotation rule must be justified, documented and, if relevant, addressed using risk mitigation measures.
Our IT systems ensure transparency, as contracts are systematically recorded and also evaluated with regard to individual contractors. We also document the approval and publication requirements. This allows us to report systematically on all procurement processes around the world.
The Alliance for Integrity is a business-driven, multi-stakeholder initiative seeking to strengthen corruption prevention in the economic system and in global supply chains. As a learning and implementation network, the initiative encourages collective action on the part of all relevant actors from the private and public sectors and civil society. The Alliance for Integrity currently works in 13 countries around the world. Its core activities include raising awareness, developing compliance capacity at small and medium-sized enterprises and improving general conditions for investment through public-private dialogue. In this process, solutions that have proven successful in one country are replicated in other regions and used to inform the global political discourse.
Embedded globally in all GIZ offices
A systematic compliance management system has been established in the entire field structure. Special compliance teams organise and manage compliance processes in countries with a potentially increased compliance risk. Responsibility for the success of these processes rests with each country director. In order to minimise risks, anti-corruption steps are introduced and their effectiveness is reviewed on a regular basis.
Raising awareness and recognising violations
Corruption is rarely recognisable at first glance. The Code of Conduct is designed to support employees in recognising and avoiding corruption risks and conflicts of interest. New staff are trained from the outset to enable them to recognise situations with a high corruption risk. Every new GIZ employee must successfully complete the company’s web-based training on ethical conduct. Classroom-based training at mandatory induction events for new staff is also used to raise awareness of possible conflicts of interest and corruption risks.
Staff members, project partners, clients and the general public can contact our internal integrity advisors, the compliance officers or an external ombudsperson in confidence to report any violations. GIZ’s tried-and-tested whistleblower system was supplemented in 2019 by an online whistleblower portal. The portal can be accessed from all over the world, is available 24/7 in several languages and can be used completely anonymously throughout the processing procedure.