The Party’s Over
Compliance Corner – Issue 2.1
Well, the party’s over. Another January’s here and none of us can believe the holidays have come and gone already. We’ll have to wait 11 whole months to celebrate International Anti-Corruption Day again!
In case you missed it, The United Nations declared December 9, 2022 as the inaugural International Anti-Corruption Day. This day “seeks to highlight the crucial link between anti-corruption and peace, security, and development. At its core is the notion that tackling this crime is the right and responsibility of everyone, and that only through cooperation and the involvement of each and every person and institution can we overcome the negative impact of this crime. States, government officials, civil servants, law enforcement officers, media representatives, the private sector, civil society, academia, the public and youth alike all have a role to play in uniting the world against corruption.”
To some, the notion that there is corruption enough to warrant the creation of a new day of observance may come as a surprise. Sure, we all remember the big corruption cases from the recent past: Watergate, Enron, the sub-prime lending scandal that led to the burst of the real-estate bubble during the early 2000s. But, trust me, 2022 will go down as more than just a blip on the Corruption Timeline.
See if these ring a bell:
- USAA (insurer for current and former military, their spouses and children) pays fines for money laundering prevention failures; $85M in 2020 and $140M in 2022
- Russia’s lawless invasion of Ukraine, with continuing atrocities
- Major banks pay $200M each for continuing to allow employee use of WhatsApp for communications about major transactions, contrary to DOJ guidance (BOA, Barclay’s, Citigroup, Credit Suisse, Deutsche Bank, Goldman Sachs, Morgan Stanley, UBS)
- Alleged misuse of Mississippi welfare funds meant for state’s poorest, used for volleyball complex sponsored by Brett Favre
- French company LaFarge prosecuted for bribery in Syria
- FTX, a major cryptocurrency company, loses $10B of investors’ money due to a “complete failure of internal controls,” says auditor who oversaw Enron Bankruptcy
- House congressional committee shows Big Oil greenwashing efforts to confront climate change
- Elon Musk fires all security and compliance personnel at Twitter
- Qatari bribery scandal involving European Parliament
- Guatemala’s former president and vice president convicted on fraud and conspiracy charges
- Prosecutions of those responsible for January 6 insurrection and seditious conspiracy to overthrow US election continue
And that’s the short list. The truth is, corruption happens all the time; in big ways, like in the headline-grabbing events above, and in not-so-big ways.
So, how can we stop it?
The UN was on to something when they said,
At [corruption’s] core is the notion that tackling this crime is the right and responsibility of everyone.
Everyone? Really? Well, yes. Any school-aged child can tell you the difference between right and wrong; we all know the basics. But sometimes we need a reminder.
That’s where ethics and compliance programs come into play. It’s not a coincidence that these programs got their start as a response to the scandals that rocked the defense industry during the 1970s; contractors were running rampant and corruption was rife. It was time to put the brakes on the baddies who were growing rich through corruption.
Many organizations, including institutions of higher education, created codes of conduct and departments like VCU’s Integrity and Compliance Office to maintain and educate people about ethical conduct.
While compliance departments now exist in organizations across industries, they typically share a similar approach in the way they attempt to curb corruption. Investopedia recognizes some of the ways savvy organizations keep corruption at bay:
Education – A strong focus on teaching expected behaviors and how to alert someone when corruption is suspected.
Regulation – Establishing codes of conduct and intervening when employees break them.
Reporting – Providing an easy way for employees to report suspected corruption when they see it.
Accountability – Holding those who violate ethical behavior through corruption and other types of misconduct accountable, no matter what position they hold.
So, that compliance training you take each year? The emails you receive from the ICO, and the new Conflict of Interest and Commitment policy launching in 2023? The VCU Helpline that makes speaking up so easy, and the investigations we conduct when someone reports misconduct? All of these exist as elements of our effort in ICO to prevent and deter corruption and other misconduct here at VCU.
If you suspect corruption in the workplace, you can help fight it, too, by speaking up. Just reach out to the ICO by accessing the VCU Helpline.
It’s time to tell those involved in corruption that the party’s over.
Sources:
Chen, J. (2022, October 13). Corruption: Its meaning, type, and real-world example. Investopedia. Retrieved January 18, 2023, from https://www.investopedia.com/terms/c/corruption.asp
United Nations. (n.d.). International Anti-Corruption Day. United Nations. Retrieved January 18, 2023, from https://www.un.org/en/observances/anti-corruption-day
A message from the ICO: We’re aware that some employees experienced issues with our most recent version of the Ethics and Compliance Annual Training course. Some did not receive invitations and updates from the Talent learning management system, while others completed the training, but still ended up on – as some employees have referred to it – the naughty list. (Apparently, Talent had trouble recognizing that those employees had actually completed the course). We are working with our partners in HR to determine how this happened and to ensure it does not happen again; we want your training experience to be positive and not full of frustration. If you experienced these or other issues, we apologize for any frustration or inconvenience this may have caused, and thank you for your patience as we work to correct these issues.