The Institute attends OECD Anti-Corruption and Integrity Forum 2023

Níall Fitzgerald, Head of Ethics and Governance, shares his insights from the 11th Organisation for Economic Co-operation and Development (OECD) Anti-Corruption and Integrity Forum (the ‘Forum’), which was held in Paris on 24–25 May 2023.

The theme of the forum was “Action to impact, working together to strengthen integrity and fight corruption” and the issues addressed impact a range of policy areas and disciplines practised by professional accountants, including governance, responsible business conduct, taxation, investor and public confidence, reporting, risk management and compliance, and many others. Discussions took place on the stage and on the fringes amongst delegates and speakers where anti-corruption and integrity strategies, measures and implementation experiences across public and private sectors were openly shared. 

Some of my key takeaways from the forum include:

1. The evolving anti-corruption and integrity challenges: The opening remarks highlighted the evolving anti-corruption and integrity challenges of our time, including geopolitical instability and threats to democracy such as undue foreign influence and kleptocracy, the increasing polarisation of society and erosion of public trust because of disinformation, leadership failures and division, and the disconnect between anti-corruption commitments made and the measures that get implemented. Until recently the dialogue around corruption focused mainly on bribery, but now we face many forms of it from grand corruption on a global scale being executed in a strategic and co-ordinated way to other more common and smaller opportunistic frauds.

2. The accountancy profession: Professional accountants play a significant role in detecting and preventing corruption, creating robust risk-based compliance systems, and improving the relationship between transparency and integrity through reporting and assurance. Some contributors cautioned that such actions can quickly become ineffective if not kept up to date with the fast-evolving ways and means of committing fraud. There were also some concerns that outdated systems or those with ineffective oversight can become enablers by allowing corruption to flourish undetected beneath a veneer of compliance. However, reporting and transparency are seen as key to promoting integrity. A memorable quote in this regard was “To achieve trust we need to reveal truth and transparency”!
3. Technology for good, technology for bad: Many insights were shared on how technology is used to combat fraud and corruption, including what tools, if any, could be used and in what circumstances to use them. Digitalisation, artificial intelligence and data analytics were described as enablers and detractors in the detection and prevention of corruption and safeguarding the integrity of data. There was a lot of discussion about blockchain and tools that perform data analytics, text scraping, risk and data mining, network analysis and automated functions (e.g. bots). Fundamentally, it is not the tool that may be good or bad, rather how it is used, the integrity of its coding and how the output is interpreted. It is not good practice to invest in sophisticated tools without addressing the basic need of ensuring the integrity of the underlying data (e.g. that the data is relevant, reliable, organised and complete) or consider how the results will be interpreted. Contributors shared experiences that warned of the importance of testing for false positives generated by data analytic tools, the need to accurately define the problem to be addressed before deciding what, if any, tool is required, to focus on the weaknesses as well as the strengths during the selection of  tools during the procurement process (you don’t want to find out too late what it can’t do), and to perform a rigorous risk assessment in advance of implementing a tool. When it comes to assessing the risks and benefits of employing technology, the Devil is not just in the detail, but also in the coding! 
4. Culture matters most: Corruption is essentially driven by human behaviour but enabled by many tools, schemes and systems. Humans are considered to have achieved many great feats, including finding water on Mars, and developing artificial intelligence, but we have still not managed to eradicate corruption. Industry leaders and regulators discussed their responses to combat corruption, including examples of measures taken to create a culture of integrity. Some key highlights from discussions around culture include:
   • If organisations want to be trusted, then they must make integrity part of the strategy
   • The right tone from the top is required, including leaders who are open and feel safe talking about corruption; acknowledging the complexities and that addressing corruption requires a multifaceted approach across the organisation
   • Embedding responsibility for an organisation’s anti-corruption strategy across all areas of the business, ensuring it is not seen solely as a compliance function’s responsibility
   • Include anti-corruption and integrity as factors to be considered in decision-making across the organisation, whether significant investment decisions, procurement choices or making sales
   • A multi-stakeholder approach is essential for any integrity strategy. The main product of relationship building is trust and starting a dialogue is the early stages of developing this.
5. Stronger collaboration: The importance of collaboration between the public and private sectors is essential to effectively combat corruption. This collaboration is evident at many levels for professional accountants, for example compliance with anti-money laundering and terrorist financing requirements. Discussions also emphasised how collaboration within both these sectors is as important for combatting corruption as for promoting integrity. This can include greater co-operation between government agencies in the public sector and competitors working together in the private sector to develop common best practice or deliver initiatives that tackle industry- or sector-specific corruption and promote greater integrity and trust. 
6. Prevention is better than cure: Delegates heard some harrowing accounts of the human, societal and financial costs of corruption. The stakes are also considerably higher for organisations and the risks of corruption are strategic, operational and reputational. The governance required needs to be proportionate and relevant to the needs and resource flows of the organisation in the context of financial, social and human capital. Risk assessment is an important mechanism for an anti-corruption strategy, and there was an emphasis on reviewing and drawing conclusions from observing what people do, not just what they report. Many forum participants were forthcoming, sharing lessons learned from previous crises, including the COVID-19 pandemic and the 2008 financial crash. The case was convincing that prevention is better, and cheaper, than cure.
7. Recovering, rebuilding and reforming with integrity in Ukraine: Government representatives of Ukraine, Deputy Speaker Oleksandr Korniyenko and Deputy Minister Serhiy Derkach, discussed plans to rebuild their country and how they are going to do so by driving corruption out of the system. They see this as essential for earning the trusty of a traumatised nation and ensuring that Ukraine is built back better than before is the least the people deserve. There was an open invitation for compliance experts and advisors to help Ukraine in this endeavour by providing anti-bribery and corruption training and assisting with the development of robust compliance systems.

In addition, I spoke with several industry leaders and experts at the forum and members can expect to hear more from us on other topical issues such as beneficial ownership transparency, combatting corruption in the supply chain, support for the proposal to recognise “zero corruption” as the 18th sustainable development goal, and, in the sphere of sustainability reporting, the current practices and developments in anti-corruption reporting. These additional resources will be made available on the Chartered Accountants Ireland Ethics Resource Centre and/or the Governance Resource Centre in due course. 

Members can access further details and recordings of some of the sessions from the forum on the OECD website.

 

A useful list of resources referred to at the forum include:

• OECD Public Integrity Indicators: A benchmark government measure to combat corruption and promote integrity, comparing government commitments to actions. Ireland and the United Kingdom are included in the data.
• Transparency International Corruption Perceptions Index (CPI): A scoring based on the results of a series of corruption surveys and assessments measuring the perceived level of public sector corruption across approximately 180 countries.
• OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions: Establishes legally binding standards to criminalise bribery of foreign public officials in international business transactions and provides for a host of related measures that make this effective. It is the first and only international anti-corruption instrument focused on the ‘supply side’ of the bribery transaction. Ireland and the United Kingdom are signatory countries.
• Understanding Anti-Corruption Reporting: Published by the International Federation of Accountants (IFAC) and Transparency International UK, this report reviews anti-corruption corporate reporting by the largest publicly traded companies and highlights the urgent need for enhanced quality, reliability and comparability in this crucial area. It also raises a series of policy questions around jurisdictional differences, comparability, governance and the completeness and reliability of the information provided. 
• Stepping up the Game, Digital Technologies for the Promotion of the Fight Against Corruption – a Business Perspective: This OECD report provides an overview of various digital tools and how they are applied in practice and examples of how companies are deploying digital technology in corporate compliance and anti-corruption efforts.
• The Blue Dot Network: A voluntary certification scheme based on quality infrastructure standards as set out in the G20 Principles for Quality Infrastructure Investment, the G7 Charlevoix Commitment on Innovative Financing for Development, the Equator Principles and guidelines such as the OECD Guidelines for Multinational Enterprises.