• richard26284

Compliance: It Starts With A Village

A few weeks ago I had Mike Kenealy, COO of Insiders Integrity (here is their new website) engage in a Q and A on “Just ‘Say No’ to Bribery but Prepare First. A Front Line Story,” (link here). Last week, Mike shared with me a pro-bono project that he had started in the Philippines, totally at his own initiative, and I thought the story was worth sharing as an example of what can be done to shape ethics at the local level. Thus, below is Mike’s  guest post, with my thanks and appreciation.

Richard, Groupe Insiders initiated a unique pro-bono project this year as an opportunity to take a pro-active stand and make a meaningful difference in impacting transparency as well as positive changes in a high risk/low integrity country. One of Insiders’ areas of expertise is providing local whistle-blower lines to corporate clients and a key goal in this pro bono project is to apply this expertise to the public.

Several test countries were considered and the Philippines was selected.

Not only does The Republic of the Philippines well meet the high risk/low integrity criteria, the fact that English is widely spoken by its residents greatly enhanced effective and direct communications within a foreign setting. Plus, we view this program as an opportunity for us to affect positive change in a country where we and many of our clients conduct business, so it is truly a win/win for all.

In January of this year, Insiders partnered up with a Filipino nongovernmental organization that is chartered to fight corruption and crime. Together, we will be launching the first third party national anti-corruption reporting system in the second quarter of 2016.

A key goal is to be much more than a typical whistleblower line. For example, response center personnel will be trained on how best to capture as much human intelligence (“HUMINT”) as possible and thus develop a far more comprehensive response protocol as opposed to the typical gathering of basic information on a single incident.

Additional goals include providing individuals with an alternative way to anonymously report more comprehensive information on corrupt and other illegal activities to an independent third party. The project also will work to undercut the well-known and all too common retribution inflicted upon those who seek to expose abuses.

Our program will be largely staffed in country by a mix of intern students who are attending local law schools and universities as well as paid recent legal graduates.  In turn, these ambitious younger locals will receive valuable experience, including heightened awareness of how bribery and public corruption detrimentally impacts their country, and the opportunity to make a real difference.

The project has five key agenda items.

  1. Protection of Journalists. Groupe Insiders fervently believes that freedom of the press and the protection of journalists are essential to impact meaningful change. Without a free and robust press, corruption will continue to flourish. In the Philippines, however, the murder rates of journalists are among the highest in the world. As such, the project will tirelessly seek to gather actionable information in support of identifying the killers of journalists and to see that they are duly prosecuted.

  2. Promote positive change through transparency. The project will report information collected to the appropriate anti-corruption officials and other law enforcement agencies, including the Office of the Ombudsman, the DOJ, NBI & PNP. Information will also be shared with the local and national media organizations so at to better assure transparency and public awareness. Additionally, social media will be utilized to report and disseminate examples of corruption. Such use of social media as a vehicle to identify corrupt officials has worked successfully in other countries. The net outcome of these efforts will, in turn, pressure officials to duly act on credible information as opposed to continuing to do little more than sweep incidents under the rug.

The objective is not to conduct a name and shame campaign. Rather, it is to provide public awareness as well as encourage locals to participate, however modestly, in addressing the endemic corruption that is not only hampering their country’s economic development, but also their personal safety.

  1. Repatriate stolen and other ill-gotten assets. The Philippines has been looted for decades, and many people have first-hand as well as actionable knowledge that can assist in the recovery of ill-gotten assets. Many of these assets belong to the people of the Philippines and the project will seek to both locate and then help to amplify the recovery of looted assets.

  2. Gather valid data. Not only will information provided by whistleblowers be aggregated, but whatever other information on public sector fraudulent activities can be collected and then analyzed will also be recorded. In turn, such data will prove invaluable to expose problematic government offices, officials and activities. This data set will also give anti-corruption officials the real time ability to benchmark progress as well as to effectively and efficiently identify best practices to thwart future corruption.

The files will also be made available to other outside duly vetted organizations, such as Transparency International, Interpol, the OECD, think tanks, universities and the like so that they too can incorporate our findings into their own research, reporting and investigation activities. Additionally, this project will result in a road map that can be utilized by third parties to better discern where they can transact business effectively and honestly, as well as low integrity sectors to avoid. In other words, this is all actionable intelligence to everyone’s benefit, government, society and the government.

  1. Social Media Outreach. The Philippines is one of the world’s most social media connected countries. Through our social media campaign, we will seek to create virtual real time corruption awareness. The objective is a million knowledgeable and motivated followers in the Philippines, and such a level of public awareness can readily spur both needed reforms and encourage ethical practices by enhancing transparency.

Concurrently, corrupt politicians will be exposed along the way while honest and qualified candidates can enjoy a more transparent and level playing field where they historically competed against corrupt political dynasties and vote buying.

Richard, successful companies need to think outside of the box. Until corrupt officials are removed from office, bribery and corruption will be continue to represent major commercial risk, thwarting large scale development and investment projects which are desperately needed.



Until #corrupt officials are removed from office #corruption will remain a #compliance challenge

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Simply put, good ethical practices are ultimately good business practices to everyone’s benefits. Rural areas in the Philippines need better hospitals, power generation, and infrastructure investment which western companies bring to market. Corruption impedes investment, it impedes growth. It needs to come out of the dark, and that, Richard, is what we intend to do.



#Corruption impedes investment & growth. What is needed is local ethical #leadership

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It takes an entire village to create societal change and many companies forget that they are also members of that village. As you once wrote about, corruption occurs in “cocoons” and companies need to decide, are they in or out of that “cocoon of corruption.”

This project seeks to encourage change locally at the grassroots level and will then assist commercial entities which are already operating in low integrity countries as to pro-actively support efforts which impact positive local change for the common good. Thank you again Richard, it is a pleasure to join you and your community again.

#MikeKenealy #RichardBistrong

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