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Launched in 2000, the United Nations Global Compact is a both a policy platform and a practical framework for
companies that are committed to sustainability and responsible business practices. As a multi-stakeholder leadership
initiative, it seeks to align business operations and strategies with ten universally accepted principles in the areas of
human rights, labour, environment and anti-corruption and to catalyze actions in support of broader UN goals. With
over 7,000 signatories in more than 135 countries, it is the world’s largest voluntary corporate responsibility initiative.
www.unglobalcompact.org
Transparency International is the global civil society organization leading the fight against corruption. Through
more than 90 chapters worldwide and an international secretariat in Berlin, Germany, TI raises awareness of the
damaging effects of corruption and works with partners in government, business and civil society to develop and
implement effective measures to tackle it.
www.transparency.org
At the invitation of the UN Global Compact, Transparency International co-chaired the Taskforce that developed this
Reporting Guidance and acted as its secretariat.
Disclaimer
The UN Global Compact and Transparency International make no representation concerning, and do not guarantee,
the source, originality, accuracy, completeness or reliability of any statement, information, data, finding, interpreta-
tion, advice or opinion contained within the publication. This publication is intended strictly as a learning document.
Copyright
The material in this publication is copyrighted.
The UN Global Compact encourages the dissemination of the content for educational purposes. Content from this
publication may be used freely without prior permission, provided that clear attribution is given to UN Global Compact
and that content is not used for commercial purposes.
Acknowledgements
The UN Global Compact Office wishes to thank Transparency International and the members of the Taskforce that
developed this Reporting Guidance. It also thanks the Global Compact Local Network focal points and companies
that took part in the field-testing of this publication.
Contents
The introduction by the Global Compact of the Reporting Guidance to its thousands of signa-
tories marks a significant step for anti-corruption. The Guidance sets a new benchmark and
Transparency International recommends it to all companies as well as signatories of the Global
Compact as an essential tool for reporting on anti-corruption. We look forward to working
with the Global Compact in further promoting the Guidance and to seeing the results over time
reflected in improved reporting not only in Communications on Progress but in companies’
overall performance.
Huguette Labelle
Chair, Transparency International
Member, UN Global Compact Board
3
Even among Global Compact participants, the 10th Principle on Anti-Corruption is often identi-
fied as the most difficult to implement. Many companies do not report yet on the 10th Prin-
ciple in the mandatory annual Communication on Progress (COP).
The fallout from the financial crisis and the subsequent global economic downturn has created
an increasing demand for companies to report on non-financial matters. Much of this demand
is driven by regulators, but also by consumers and civil society organizations. And most nota-
bly, investors are increasingly considering environmental, social and governance issues, includ-
ing the implementation of anti-corruption measures, material to their investment decisions.
Beyond external factors, quality reporting on anti-corruption can effectively support the deeper
integration of anti-corruption measures into business operations by establishing an external ac-
countability mechanism and stimulating companies to improve their internal management sys-
tems. Further, reporting can allow companies to share best practice and learn from each other.
This Reporting Guidance on the 10th Principle was developed to assist companies in this often
daunting task, and I hope it will serve as a practical resource in identifying reporting priorities
on the path to performance improvement and enhanced accountability and transparency.
Georg Kell
Executive Director
UN Global Compact
4
The difficulty of reporting has been confirmed by Global Compact implementation surveys that
have found that too few Global Compact business participants report comprehensively on anti-
corruption policies and implementation mechanisms1.
In this context, the Global Compact Working Group on the 10th Principle appointed the Task-
force to create a Reporting Guidance on the 10th Principle as a tool to give practical guidance
to small, medium and large companies as they report on their efforts.
This Reporting Guidance was created over the course of 15 months (from September 2008 until
November 2009) by the Taskforce which included non-governmental organizations,
anti-corruption experts and business practitioners:
Extensive consultation was conducted to ensure the usefulness and user-friendliness of the
Reporting Guidance, such as:
■■ anonymous field testing over a period of three months by Global Compact participants
(companies and Global Compact Local Networks);
■■ individual consultations with other Global Compact Local Networks (mainly from emerging
markets) and the investment community.
The Reporting Guidance thus represents a global, multi-stakeholder endeavour to extend the
reporting of companies’ anti-corruption efforts in their Communications on Progress (COP).
On 24 June 2004, the first Global Compact Leaders’ Summit announced that the
Global Compact, the world’s largest corporate sustainability initiative, had adopted a
10th Principle against corruption: “Businesses should work against corruption in all its
forms, including extortion and bribery.” The adoption of the 10th Principle sent a strong
worldwide signal that the private sector and other non-state-actors share responsibil-
ity for eliminating corruption and stand ready to play their part. The 10th Principle
commits Global Compact participants not only to avoid bribery, extortion and other
forms of corruption, but also to develop policies and concrete programmes to address
it. Companies are challenged to join governments, UN agencies and civil society to
realize a more transparent global economy.
The 10th Principle was the response of the business community and other non-state
actors to the adoption of the United Nations Convention against Corruption. The UN
General Assembly adopted the Convention in October 2003, and it entered into force on
14 December 2005. As of September 2009, over 140 States had ratified the Convention.
As the sole global, legally binding anti-corruption instrument, the Convention provides a
unique opportunity to prevent and fight corruption in both public and private sectors.
With this in mind, the 2004 Global Compact Leaders’ Summit designated the UN
Convention against Corruption as the underlying legal instrument for the new 10th
Principle. In fact, while the Convention is legally binding only for countries that have
ratified it, its values and principles are applicable to the widest spectrum of society, in-
cluding the business community. The principles enshrined in the Convention can serve
as an inspirational tool for companies adopting or reviewing internal anti-corruption
policies, strategies, and measures.
Following adoption of the 10th Principle, the Global Compact established a multi-
stakeholder working group to provide strategic input to the Global Compact’s work on
anti-corruption and to define the needs of the business community in implementing the
principle. The Working Group on the Implementation of the UN Global Compact’s 10th
Principle also aims to contribute to greater coherence by supporting the alignment of
existing initiatives and avoiding the duplication of efforts.
The Working Group has established several task forces to develop various tools and
resources to help businesses achieve the goals of the 10th Principle. This Guidance is
the result of one such effort.
6
The objective of this Reporting Guidance is to set out and promote the strong benefits
of reporting on anti-corruption in the Communication on Progress by providing a structured
and comprehensive guidance document that encourages thorough and consistent reporting
of anti-corruption efforts by signatories.
The Global Compact invites you to use the Reporting Guidance in developing your COP and
to describe activities and outcomes in an aligned manner and thereby share your experiences
and endeavours.
While the Reporting Elements require descriptive reporting, some propose that you addition-
ally provide quantitative reporting (e.g., number of employees trained); however, the key as-
pect is to illustrate practical actions (i.e., activities undertaken, outcomes achieved or expected)
that you have taken to implement the 10th Principle. Consequently, the Reporting Guidance
focuses mainly on descriptive Reporting Elements, such as a description of responsibility
assigned to oversee and implement your anti-corruption programme.
■■ Business Case for reporting on the 10th Principle: This section explains and underscores the
benefits of reporting on the implementation of the 10th Principle. (pages 10-11)
■■ Reporting Elements for the 10th Principle: This section sets out a list of Basic and Desired
Reporting Elements for the 10th Principle. Each Reporting Element is supplemented with
practical guidance on the importance of the Element, how to implement it and examples of
what to report on. (pages 12-33)
Finally, the Appendices provide further practical guidance with a summary of examples for use
in your reporting against relevant Reporting Elements, details of five initiatives offering report-
ing indicators on anti-corruption (FTSE4Good, the Global Reporting Initiative, the International
Corporate Governance Network, the Partnering Against Corruption Initiative and Transparency
International) and a list of other Global Compact resources related to the 10th Principle.
7
2. Communication on Progress
While the Global Compact is a voluntary initiative, it includes a mandatory disclosure frame-
work for business participants. Companies committed to implementing the Global Compact
principles are required to communicate on their implementation through an annual report,
known as the Communication on Progress (COP). The COP can serve as a learning tool, but can
also be seen as a basis for public dialogue and an effort towards greater accountability. COPs
are published on the Global Compact website and many show good practices or inspirational
examples of corporate implementation.
The COP is based on concepts of public accountability, transparency and continuous perfor-
mance improvement. COPs are important because they:
■■ enhance the credibility and value of an organization’s participation in the Global Compact;
■■ serve as a source of information for stakeholders on an organization’s environmental, social
and governance activities and performance;
■■ facilitate learning and information sharing for Global Compact participants;
■■ contribute to the development of a useful collection of organizational practices;
■■ drive change in organizations; and
■■ protect the integrity and accountability of the Global Compact.
Year-on-year reporting
Organizations are required to provide COPs annually and focus on progress made year-on-year.
When you first use this Reporting Guidance and its new structure of Basic and Desired Report-
ing Elements you may already have reported in previous COPs on some of the topics covered in
the Reporting Elements. However, to enable readers of COPs to assess your progress on anti-
corruption measures, you are encouraged to report again information that you have previously
reported or provide a link to where the information can be found on your website.
For subsequent years, you need not repeat previous reporting but you should indicate in which
year the information was provided in a COP and the link to where the information can be
found.
2 http://www.unglobalcompact.org/AboutTheGC/publications.html#COMMUNICATION%20ON%20PROGRESS
3 For more information read Making the Connection - Using GRI's G3 Guidelines for the COP
http://www.unglobalcompact.org/docs/communication_on_progress/4.3/Making_the_connection.pdf
4 http://www.unglobalcompact.org/COP/
9
10
The integration of a clear anti-corruption commitment into the corporate responsibility agenda
sends a strong signal that the private sector shares responsibility to address and counter corrup-
tion. Yet, countering corruption remains a serious challenge for implementation, monitoring
and reporting, owing to the complex and hidden nature of the issue, but also partly because of
the lack of a practical reporting guidance.
At the same time, public reporting on anti-corruption is not only an important way of demon-
strating the sincerity of the corporate commitment to the Global Compact’s 10th Principle. It
can also provide substantial benefits, such as strengthening internal anti-corruption systems
through increased transparency, enhancing reputation and providing a common basis for mea-
suring progress and learning from your peers.
There are three major benefits from reporting on anti-corruption. The first two categories apply
to individual organizations (independent of their size), whereas the third category outlines
benefits also for the overall community.
Formalized and consistent reporting on anti-corruption activities, integrated into already estab-
lished reporting processes (e.g., accounting), ensures reliable and measurable internal opera-
tions. It shows to employees that the fight against corruption is taken very seriously (“What
gets measured gets done”). This results in the following benefits:
2. Enhanced reputation
By reporting levels:
■■ Basic Reporting Elements: These 7 Elements are considered to be the basic level of
reporting on an organization’s anti-corruption policies and procedures;
■■ Desired Reporting Elements: These additional 15 Elements give you the opportunity to
report more extensively on your anti-corruption policies and procedures.
By categories:
■■ Commitment and Policy: how your organization has committed to a
zero-toleration of corruption;
Basic Desired
Reporting Elements Reporting Elements
Commitment
B1-B2 D1-D5
and Policy
Monitoring B7 D12-D15
Your organization is encouraged to develop its own anti-corruption practices and report against
the Reporting Elements as the process of developing content for reporting will in itself assist
your organization in reviewing and improving anti-corruption policies and programmes.
13
Additionally, you can choose to report on one or more of the 15 Desired Reporting Elements,
depending on the extent of your reporting systems and progress made in implementing the
10th Principle against Corruption. In this way, as an increasing number of organizations report
on their practices, other organizations can use these examples to improve their own anti-
corruption programmes.
For each Reporting Element, a description explains its importance, details how it is usually
implemented, and presents examples, both qualitative and quantitative, of what to report on.
The examples illustrate the types of information that can be reported on, and are neither an
exhaustive list nor a list of minimum requirements. Appendix A provides a summary of the
examples of what to report on for each of the 22 Reporting Elements.
Finally, each Reporting Element includes an example of a reporting indicator from another ini-
tiative, such as the Global Reporting Initiative. The examples show that the Reporting Elements
are rooted in existing practice and reporting on the Elements will help when reporting against
indicators of other initiatives.
The Global Compact asks reporting companies to reference the Reporting Guidance when de-
veloping a COP, e.g., in the index of a sustainability report.
The next section provides an overview of the 22 Reporting Elements in the easy-to-apply matrix
and is then followed by detailed guidance for each of the Elements, grouped by the three
categories:
For each category, the Basic Reporting Elements are listed first, followed by the
Desired Reporting Elements.
14
Commitment to be in compliance with all relevant laws, Statement of support for international and regional legal
B2 D2
including anti-corruption laws frameworks, such as the UN Convention against Corruption
Implementation
Communication and training on the anti-corruption com- Human Resources procedures supporting the anti-corruption
B5 D8
mitment for all employees commitment or policy
Internal checks and balances to ensure consistency with Communications (whistleblowing) channels and follow-up
B6 D9
the anti-corruption commitment mechanisms for reporting concerns or seeking advice
Monitoring
B7 Monitoring and improvement processes D12 Leadership review of monitoring and improvement results
How to implement:
Public commitment can be shown in various Example of reporting indicators from
ways: public declaration by the organiza- other organizations:
tion (e.g., by the CEO, Board or equivalent ■■ Organization: Partnering Against Corrup-
body, owner or management) through such tion Initiative (PACI)
channels as annual shareholder meetings ›› R
eporting indicator: No. 6: Does your
and reports, interviews, management letters company publish its anti-corruption com-
circulated to each employee, public meetings, mitment externally, i.e. on its website
departmental meetings, supplier and other and/or in its annual report?
business partner communications, state-
ments on the internet and intranet, keynote
speeches to and from heads of business units.
the UN Convention against Corruption and ■■ Describe where these policies can be found
on various voluntary instruments5 that cover, and how they are made available to all em-
among others, conflict of interest, money ployees and business partners concerned.
laundering, embezzlement, gifts, hospitality
and travel, donations, sponsorships, social Cross-reference to Reporting Elements
and community investment, facilitation pay- within this Guidance:
ments, political contributions, interactions None.
with government officials and lobbying, and
dealings with business partners, agents and
other intermediaries, joint ventures use of the Example of reporting indicators from
organization’s assets, mergers, acquisitions other organizations:
and minority interest. ■■ Organization: Transparency International
›› R
eporting indicator: Indicator No. 29: Is
What to report (Examples): there a written policy covering political
■■ List the areas of potential risk of corruption contributions whether made directly or
which are covered by detailed anti-corrup- indirectly?
tion policies.
5 Such as the International Chamber of Commerce Rules of Conduct, the World Economic Forum/Partnering Against Corruption Initiative and
the Business Principles for Countering Bribery, and the Wolfsberg AML Principles.
Implementation
22
2. Implementation
B3 Translation
actions
of the anti-corruption commitment into
message.
What to report (Examples): ment and this will form part of the process of
■■ Describe the internal controls policies and continuous improvement covered by Report-
processes (e.g., frequency, scope of organi- ing Element B7.
zational coverage, degree of control auto-
mation, international frameworks used).
■■ Report whether internal and external au- Example of reporting indicators from
dits have taken place. other organizations:
■■ Report on the specific mandates given to ■■ Organization: International Corporate
Monitoring
30
3. Monitoring
(e.g., who has ultimate oversight, who con- tion Initiative (PACI)
ducts the review, who reviews the results, ›› R
eporting indicator: No. 1: Does your
frequency of reviews). corporate executive management review the
■■ Describe actions taken, including improve- evaluation of your company’s anti-corrup-
ment results. tion programme?
How to implement:
It is advisable to devise a process setting out Example of reporting indicators from
the steps to be taken to deal with incidents, other organizations:
such as: ■■ Organization: International Corporate
■■ Procedures, roles, rights, responsibilities for Governance Network (ICGN)
investigations; ›› R
eporting indicator: Question No. 24:
■■ Investigation by a dedicated corporate Does the company have internal reporting
team; processes to the board or appropriate board
■■ Documented investigation; committee on the number and types of
■■ Reporting of findings to the leadership; relevant incidents that have been detected
■■ Remedial steps or sanctions taken against and remedial actions taken?
relevant employees;
■■ Appropriate disclosure to relevant
authorities;
■■ Suspension of contracts or payments to any
an external assurance, i.e., if assurance has pany externally publish the results of anti-
been on the programme design and/or ef- corruption assurance provided by external
counterparts?
34
35
This table provides a summary of practical examples for use in your reporting against relevant Reporting
Elements. It must be stressed that this is neither an exhaustive list nor a list of minimum requirements, but
rather a selection of examples to assist you in developing your own reporting.
Commitment and Policy: Publicly stated ■■ Provideyour organization’s statement against corruption.
B1 commitment to work against corruption in ■■ Describewhere the statement can be found publicly (e.g., website, corporate
all its forms, including bribery and extortion citizenship report).
Commitment and Policy: Commitment ■■ Provide a public written statement that you are committed to be in compliance
B2 to be in compliance with all relevant laws, with all relevant laws and indicate where this statement is published.
including anti-corruption laws ■■ Describe your procedures and efforts with regard to that statement.
■■ Describespecific internal checks and balances such as approval policies and pro-
Implementation: Internal checks and
cesses, audit plans, expense and invoicing guidelines, etc., aimed at detecting and/
B6 balances to ensure consistency with the
or preventing corruption and how these support your anti-corruption commitment.
anti-corruption commitment
■■ Describe how often you review these internal checks and balances.
Commitment and Policy: Statement of ■■ Describe general statements of support for international and regional frameworks;
support for international and regional legal making specific mention of the treaty or framework supported.
D2
frameworks, such as the UN Convention ■■ Describe your organization’s initiatives, if any, to mark the annual International
against Corruption Anti-Corruption Day (9 December).
■■ Describe your current risk assessment procedures (e.g., how often it is carried out,
Commitment and Policy: Carrying out who is in charge, which parts of your organization are covered, how results are
D3 risk assessment of potential areas of cor- dealt with).
ruption ■■ Describe the business units and subsidiaries for which a risk assessment has been
undertaken.
■■ Listthe areas of potential risk of corruption which are covered by detailed anti-
Commitment and Policy: Detailed poli- corruption policies.
D4
cies for high-risk areas of corruption ■■ Describe where these policies can be found and how they are made available to all
employees and business partners concerned.
■■ Outline your definition of business partners (e.g., suppliers, agents, joint ventures).
■■ Describe how your organization’s anti-corruption commitment extends to business
partners as well as how anti-corruption commitments from your business partners
Commitment and Policy: Policy on anti- extend to your organization.
D5
corruption regarding business partners ■■ Describe your identified high-risk business partners by industry (e.g., public sector).
■■ Describe the coverage of your supply chain related to the extension of the anti-
corruption policy (identified sizes or types of suppliers, producers).
■■ Specify detailed policies for business partners.
■■ Outline your definition and scope of business partners (e.g., suppliers, agents,
joint ventures).
Implementation: Actions taken to encour- ■■ Describe specific communication measures and actions, such as training taken to
D6 age business partners to implement anti-
encourage your business partners to implement anti-corruption programmes.
corruption commitments ■■ Describe the process of monitoring the effectiveness of such communication
measures and actions.
■■ Describe the internal controls policies and processes (e.g., frequency, scope of
organizational coverage, degree of control automation, international frameworks
Implementation: Internal accounting
used).
D10 and auditing procedures related to anti-
■■ Report whether internal and external audits have taken place.
corruption
■■ Report on the specific mandates given to the audit function, internal and external
where applicable.
■■ Describethe oversight of the review process (e.g., who has ultimate oversight,
Monitoring: Leadership review of monitor-
D12 who conducts the review, who reviews the results, frequency of reviews).
ing and improvement results
■■ Describe actions taken, including improvement results.
■■ State that there is a process in place for dealing with incidents including
remedial steps.
D13 Monitoring: Dealing with incidents ■■ Describe the process.
■■ State the nature and number of incidents dealt with and number of
disciplinary actions.
■■ List
in a corporate publication (such as your annual report or sustainability
Monitoring: Public legal cases regarding report or on your website) any current public investigations, prosecutions or
D14
corruption closed cases (take care to avoid stating any information that may be misleading
or compromising).
International Corporate Governance Network (ICGN) ICGN Statement and Guidance on Anti-Corruption Practices, 2009
The Global Compact offers further guidance, tools and publications related to anti-corruption,
which can be consulted as complementary documents or used as inspirational examples.6
The publication Fighting Corruption through Collective Action describes how companies can reach
out to industry peers, suppliers and other stakeholders to initiate joint activities against corrup-
tion, particularly in high-risk regions and sectors. It provides concise guidelines and practical
examples through case summaries.
Business Fighting Corruption: Experiences from Africa11 represents a collection of case studies show-
casing how organizations and businesses in Africa are addressing the challenge of corruption.
The publication aims to assist managers in fighting corruption and increasing transparency.
Transparency International
International Secretariat
Alt-Moabit 96
10559 Berlin
Germany
Phone + 49 30 3438 200
Fax + 49 30 3470 3912
www.transparency.org
PHOTO CREDITS:
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The Ten Principles of the
United Nations Global Compact
Human rights
Labour
Environment
Anti-corruption