i2a Publishes the Results of its 2010 Survey of Business Codes of Conduct Against the Backdrop of the UK Bribery Act
i2a Consulting’s latest survey of business codes of conduct indicates that considerable improvement in the standard of many codes is needed to meet the likely requirements of the UK Bribery Act that will come into effect next year. The survey looked at 10 criteria ranging from ease of access to the degree to which the code of conduct sets expectations for individuals. The full list of criteria and their definitions are available at i2a Code of Conduct – Criteria
The Secretary of State has recently published guidance on the procedures that commercial organisations can put in place to prevent bribery.
The guidance sets out six principles, the fourth of which is the the need for “clear, practical and accessible policies and procedures”, at the heart of which lies an organisation’s code of conduct. The drafting of this principle was no doubt informed by a draft paper provided to Lord Bach by representatives of GC100, a group which brings together the senior legal officers of more than 85 FTSE 100 companies. Section 4 of the GC100 guidance states:
“Commercial organisations should have a clear and unambiguous code of conduct which includes an anti-corruption element, should publicise this code adequately internally, and should publish the code on its website”.
While consultation on the ‘adequate procedures’ guidance is currently taking place prior to its planned publication early next year, it can be assumed that the need for clear, practical and accessible policies and procedures will remain central to it.
Our survey, which covers 64 companies in the Energy, Pharma, Insurance, Banking and Defence sectors reveals great variation in quality of these codes of business conduct, from the very good to the very poor. Many cannot claim to be clear and unambiguous and are often hard to obtain.
The Survey Results
As with 2009 Morgan Stanley maintain the top position but this year are joined by Lilly and Co, taking part in the survey for the first time. Both companies scored an impressive 49 points out of 50. Close behind were BAE Systems with 47 points, Standard Chartered with 46 and Rolls Royce with 45. The pharmaceutical sector averaged 37 points, whilst the average for the oil and gas sector was just 29. Numerous companies scored below half marks. The full results can be obtained from info@i2a.co.uk
This blog was written by Alan Holroyd
