Our fight against corruption

As a public-benefit federal enterprise in the field of sustainable development, GIZ is in the public eye worldwide. We have a high level of accountability for the funds entrusted to us.

Using taxpayers’ money responsibly and protecting it against corruption are top priorities. Corruption involves high risks of criminal prosecution for individuals and immense reputational risks for companies. The mere suggestion of corruption can be damaging. As awareness of corruption rises among policy-makers and civil society, the range of commissioning parties and clients broadens, and commissions and projects grow more and more complex, GIZ is increasingly called upon to reinforce its commitment to ensure that it acts with integrity, complies with the rules, and actively combats corruption. For this reason, our framework conditions are designed to prevent corruption.

Photo: Two women standing at a marker board. One writes, the other looks on. — © GIZ / Sabrina Asche

Anti-corruption at GIZ

Corruption has many facets. At GIZ, we define it as the abuse or misuse, for personal gain, of the power conferred by public office or through private sector authorisations. This includes giving and accepting bribes, embezzlement, nepotism, fraud or kickback payments, i.e. the payment of commissions between the parties involved in a transaction. Certain conflicts of interest can also constitute a form of corruption.

At GIZ, we have an anti-corruption management system that enables us to proactively tackle the problem. Its goal is to foster an anti-corruption culture, which permanently hones awareness of corrupt actions and encourages all staff to take measures against incidents of this sort. Anti-corruption management is a key component of GIZ’s compliance management system.

For the projects that we realise on behalf of the German Federal Ministry for Economic Cooperation and Development (BMZ), we are also guided by its quality criteria strategy on anti-corruption and integrity. In addition, we are a corporate member of Transparency International.

Embedded globally
in all GIZ offices

GIZ has established a systematic compliance management system across its entire field structure and at the Head Office. Special compliance teams organise and manage additional compliance processes in countries with a potentially increased compliance risk. Responsibility for implementing these processes rests with each country director. In order to minimise any risks identified, appropriate countermeasures 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 identifying and avoiding corruption risks and conflicts of interest. New staff are sensitised from the outset to recognise situations with a high corruption risk. All new GIZ staff must successfully complete the basic online compliance module, and there is also a compulsory module specifically for managers, which they must repeat every three years.

Members of staff, project partners, clients and commissioning parties and members of the general public wishing to report a possible violation can contact the compliance officers and an external ombudsperson in confidence. An online portal has been added to GIZ’s tried-and-tested whistleblower system. It can be accessed from all over the world, is available in several languages 24/7, and can be used anonymously throughout the processing procedure.

Below you will find information about the Global Reporting Initiative’s (GRI) sustainability standards on the vital topic of compliance and anti-corruption:

GRI 2: General Disclosures 2021

GRI			UNGC	SDG	DNK
2-1-a	Legal name	Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ) GmbH
2-1-b	Nature of ownership and legal form	Shareholder Legal information
2-1-c	Location of headquarters	Friedrich-Ebert-Allee 32 + 36 53113 Bonn Dag-Hammarskjöld-Weg 1–5 65760 Eschborn Germany
2-1-d	Location of operations	GIZ has two registered offices in Germany, one in Bonn and one in Eschborn. The company also operates at nine other locations in Germany and in over 120 countries around the globe. Worldwide
2-9	Governance structure and composition	The Supervisory Board has put the following committees in place: Audit Committee, Standing Committee, Urgent Matters Committee. Composition of the Supervisory Board: Executive/non-executive members, their positions/responsibilities and skills: Supervisory Board (giz.de) Stakeholders: The representatives of the Shareholder currently comprise four members of the Budget Committee of the German Federal Parliament, five representatives of the German Government (Federal Ministry for Economic Cooperation and Development, Federal Ministry of Finance, Federal Foreign Office, Federal Ministry for Economic Affairs and Climate Action, Federal Ministry for the Environment, Nature Conservation, Nuclear Safety and Consumer Protection) as well as one representative of the Deutsche Stiftung für internationale Entwicklung (DSE) from the Bavarian State Chancellery. Independence: The rules of procedure of the Supervisory Board stipulate that members are required to act in the best interests of the company. Their decisions may not be swayed by personal interests or by any efforts to exploit business opportunities to which the company is entitled for their own benefit. Conflicts of interest, particularly such that might arise as a result of advising or sitting on an official body of clients, suppliers, lenders or any other business partners, must be disclosed to the Supervisory Board. Term of office: Generally, the members of the Supervisory Board are appointed for the period ending with the conclusion of the Shareholder’s meeting that decides on the granting of formal approval of activities for the fourth financial year after the beginning of the term of office. The financial year in which the term of office begins is not included. The Supervisory Board has achieved gender parity. No information on social groups is recorded with respect to the Supervisory Board.	7, 8, 9	1–17	3, 5
2-10	Nomination and selection of the highest governance body	The GIZ Supervisory Board consists of 10 Shareholder representatives and 10 workforce representatives (thus a total of 20 members). The members of the Supervisory Board representing the Shareholder are appointed and dismissed by the Shareholder. The workforce representatives are elected by GIZ staff in line with the provisions of the German Co-determination Act (Mitbestimmungsgesetz). The most recent election was held in August 2022. The 10 workforce representatives consist of three trade union representatives, one executive manager and six employees.		16	5
2-12	Role of the highest governance body in overseeing the management of impacts	Values, strategies and objectives are set by the Management Board, the Management Committee, the Strategy Committee and the Sustainability Board. Strategic leadership is not the role of the Supervisory Board.		16	5
2-13	Delegation of responsibility for managing impacts	The foundation for the decentralised implementation of our Sustainability Programme is a well-functioning governance structure to steer the process. This structure consists of the Sustainability Office, the Sustainability Board and the Director Corporate Sustainability. Together, they continue to hone GIZ’s sustainability management. The staff of the Sustainability Office also advise and support the organisational units and the field structure on sustainability matters and ensure that knowledge is shared within GIZ. The overarching responsibility for sustainability is vested in the Chair of the Management Board, who also chairs the Sustainability Board comprising the directors and directors general of various units and departments. This underscores the paramount importance that GIZ attaches to sustainability management.	1, 2, 6, 7, 8, 9	7, 12, 13, 15, 16	1, 2, 3, 6, 7, 12, 13, 14, 17
2-15	Conflicts of interest	The rules of procedure of the Supervisory Board stipulate that members are required to act in the best interests of the company. Their decisions may not be swayed by personal interests or by any efforts to exploit business opportunities to which the company is entitled for their own benefit. Conflicts of interest, particularly such that might arise as a result of advising or sitting on an official body of clients, suppliers, lenders or any other business partners, must be disclosed to the Supervisory Board. Should a Supervisory Board member declare a conflict of interests, a discussion of how to address this issue should be held without delay and a decision taken on how to proceed. In the spirit of the German Government’s Public Corporate Governance Code (PCGK), GIZ ensures that members can meet their responsibilities as part of the Supervisory Board. Accordingly, members are not supposed to hold more than three posts simultaneously in supervisory bodies.		16	5
2-16	Communication of critical concerns	Where critical concerns arise within the sphere of responsibility of the Supervisory Board, these concerns are addressed in the form of regular or special reports or through business transactions subject to approval.	10	16	5, 20
2-17	Collective knowledge of the highest governance body	Under the provisions of the German Government’s Public Corporate Governance Code (PCGK), GIZ is required to issue a non-financial declaration and submit it to the Supervisory Board for scrutiny. In 2022, this took the form of the Declaration of Conformity with the German Sustainability Code, including the non-financial declaration. Reports are published once a year.		16, 17	9, 14
2-18	Evaluation of the performance of the highest governance body	The performance of the Supervisory Board is not evaluated by any third party.		16	5

Material topic 8: Compliance and anti-corruption

GRI			UNGC	SDG	DNK
3-3	Management approach disclosures	Our Code of Ethics, which contains GIZ’s key ethical principles, 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. In signing their employment contract, all members of our workforce commit to comply with the Code of Ethics and the Code of Conduct. GIZ also has an anti-corruption policy, which is an expression of our zero tolerance policy towards corruption. • Our anti-corruption management is operationalised in a work programme that sets out concrete steps and measures. In 2021, GIZ conducted a comprehensive, company-wide activityto identify working areas particularly vulnerable to corruption. The potential for enhancing corruption prevention identified herein is being addressed and implemented in follow-on processes in 2022 and 2023. The objectives are: To obtain a company-wide automated overview of all working areas particularly vulnerable to corruption by the end of 2023 To adapt the policy on staff rotation by the end of 2023. We analyse on an ongoing basis whether we need to modify our anti-corruption management to meet the requirements of our commissioning parties. Equally, we continually analyse which requirements GIZ needs to pass on to business partners. All contracts with service providers and consultants are subject to strict rules with a view to minimising corruption risks. Systematic Compliance Management GIZ is expanding its compliance management system to ensure compliance, integrity and anti-corruption. The Compliance and Integrity Unit coordinates and manages the system in collaboration with all the relevant organisational units. It 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 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. Ongoing identification of compliance, integrity and corruption risks both in Germany and the field structure is part of the standard, company-wide risk management process. Countries at high risk report both on individual compliance risks and on the overall picture. By analysing and assessing existing and potential risks, the need for action in this area is systematically identified and addressed as part of a risk-based compliance programme. GIZ follows up on any tip-offs about risks and where necessary adapts its internal Processes and Rules. It puts measures in place to prevent, investigate and respond to issues. Our internal control system and comprehensive rules also ensure proper commercial management of our projects. We check regularly whether the financial and administrative procedures 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 subject 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 this rule must be justified, documented and, if relevant, risk-mitigation measures must be put in place. 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. All of this helps limit any adverse impacts on our efforts to stamp out corruption and bribery. Further information Our fight against corruption	10	16	20

GRI			UNGC	SDG	DNK
205-1	Operations assessed for risks related to corruption	The assessment of significant compliance risks, which include the level of corruption, are updated annually for country offices in the field structure. In 2022, assessments covered 97 countries in which GIZ operates. That is equivalent to 100 per cent of operations outside Germany, and 97 per cent of our total of 100 operations. Within the scope of the assessment of significant compliance risks in the field structure, which includes corruption risks, the countries in which GIZ operates are subdivided into risk categories. The action that is required in the standard processes used by the country offices to address the compliance risks identified differs as a result. In 2022, however, all country offices, irrespective of their compliance risk category, were required to produce an additional in-depth compliance risk analysis and identify appropriate risk-mitigating measures.	10	16	20
205-3	Confirmed incidents of corruption and actions taken	The total number of confirmed incidents of corruption in 2022 stood at 1 (internal actor, bribery). The offender was dismissed. There were no incidents of contracts with business partners being terminated or not renewed due to violations related to corruption. No public legal cases regarding corruption were brought against GIZ or its staff members.

GRI			UNGC	SDG	DNK
3-3	Management approach disclosures	GIZ does not donate to any political parties, politicians or associations affiliated to political parties. We thus comply with the requirement to exert no political influence.	10		19
415-1	Political contributions	GIZ does not donate to any political parties, politicians or associations affiliated to political parties. We thus comply with the requirement to exert no political influence.	10	16	19

GRI			UNGC	SDG	DNK
3-3	Management approach disclosures	See GRI 205: Anti-corruption 2016	10		20
419-1	Non-compliance with laws and regulations in the social and economic area	No cases of non-compliance with laws and regulations were identified during the 2022 reporting period. Annual GIZ Compliance Report 2021

GRI			UNGC	SDG	DNK
		See ‘Material topic 2: Protection of natural resources’

Additional relevant information about the GRI, the German Sustainability Code and the Global Compact can be found here
Management Board’s declaration on compliance
Ethics and Integrity
Whistleblowing
Submit a report
Anti-corruption
Compliance management system
GIZ Code of Ethics

Anti-corruption at GIZ

Embedded globally in all GIZ offices

Raising awareness and recognising violations

Below you will find information about the Global Reporting Initiative’s (GRI) sustainability standards on the vital topic of compliance and anti-corruption:

GRI 2: General Disclosures 2021

Material topic 8: Compliance and anti-corruption

GIZ uses tracking technologies from various providers

Embedded globally
in all GIZ offices

Raising awareness and
recognising violations