34886156


Anti-Corruption Programme for Professional Institutions

Professional institutions help to ensure the integrity of their professions and can have a material impact in the fight against corruption.

This Section of the GIACC Resource Centre contains resources which can assist a professional institution:

  • play a leadership role in the fight against corruption in the countries, regions and sectors in which they have interests; and
  • take reasonable steps to ensure that their members and employees do not participate in corruption.

Section A below contains a recommended anti-corruption programme for professional institutions.

Section B below recommends resources which professional institutions can use to support them in their anti-corruption programme design and implementation. 

Section C below explains GIACC’s alliance arrangements, under which GIACC forms alliances with professional institutions so as to support them in implementation of their anti-corruption programme.

The professional institution should ensure that its anti-corruption programme complies with any applicable requirements specified by law.

GIACC uses the term “corruption” in this programme to include bribery, extortion, fraud, cartels, abuse of power, embezzlement, and money laundering.  These are criminal offences in most jurisdictions.   See What is Corruption for further explanation of these offences.

A:  ANTI-CORRUPTION PROGRAMME FOR PROFESSIONAL INSTITUTIONS

1.  Providing top-level leadership

  • The President, Chief Executive and other leading representatives of the professional institution (“institution”) should publicly on behalf of the institution:
    • denounce corruption as being wrong and unacceptable
    • highlight the damage caused by corruption
    • advocate the need for effective anti-corruption action
    • commit the institution to taking and supporting appropriate anti-corruption action
    • support the implementation by the institution of this anti-corruption programme
    • emphasise the obligation on members and employees:
      • to comply with an anti-corruption code of conduct (see 4)
      • to report to the institution if they suspect that a breach of the anti-corruption code of conduct has been or is about to be committed by any of its members or employees (see 6).
  • This top-level leadership can be achieved through a personal statement on the institution’s website, presentations at conferences, press interviews, newspaper articles, and newsletters to members and employees.

2.  Appointing an Anti-Corruption Leader

  • The institution should appoint an Anti-Corruption Leader (or similar appropriate title) who is a senior member of the institution and who will lead the implementation of the institution’s anti-corruption programme.
  • The Anti-Corruption Leader should have:
    • a high level of personal integrity
    • considerable experience of the institution’s sector and activities
    • a commitment to the anti-corruption programme
    • enthusiasm and energy to promote the anti-corruption programme
    • a belief that corruption can be materially reduced if appropriate action is taken.
  • The Anti-Corruption Leader need not be a full time or paid role. The role could, for example, be assumed by a past President or retired member of the institution.

3.  Promoting implementation of anti-corruption measures in the institution’s sector

  • The institution should collaborate with key stakeholders in the institution’s sector to:
    • develop and improve anti-corruption measures designed to reduce corruption
    • promote the implementation and enforcement of these measures
    • achieve effective compliance with these measures.

Such collaboration could take place, for example, through conferences, workshops, meetings, and oral, written and on-line communication.

  • These anti-corruption measures should:
    • help ensure that all stakeholders in the institution’s sector operate free from corruption and with honesty, integrity, transparency and accountability
    • require and enable all stakeholders in the institution’s sector to implement in relevant organisations management controls which are designed to prevent, detect and deal with corruption both within the organisation and in the organisation’s external dealings (such as with its clients, partners, contractors, suppliers and consultants). These controls should include personnel controls and training; risk assessments and due diligence; procurement, financial and commercial controls; audits; reporting, investigation and disciplinary processes; and transparency requirements. 
  • “Key stakeholders in the institution’s sector” include:
    • government departments
    • public and private sector organisations, including professional institutions, project owners, funders, contractors, suppliers and consulting engineering firms
    • individuals working within those departments and organisations.

4.  Requiring members and employees to comply with an anti-corruption code of conduct

  • The institution should establish an anti-corruption code of conduct, and require its members and employees to comply with this code as a condition of membership or employment.
  • The anti-corruption code of conduct may be a stand-alone document, or it may be included in a wider code which also covers other professional requirements applicable to the institution’s members and employees, such as in relation to quality, health and safety, environmental protection, discrimination, and human rights.
  • The anti-corruption code of conduct should:
    • comply with any applicable requirements specified by law
    • require the institution’s members and employees inter alia to:
      • act with honesty and integrity
      • avoid corruption
      • avoid conflicts of interest
      • comply with all applicable anti-corruption laws and standards
      • report to the institution where they suspect that a member or employee of the institution has committed or is about to commit a breach of the anti-corruption code of conduct (see 6)
    • be published in an easily accessible location on the institution’s public website so that members and employees of the institution and members of the public are aware of the provisions of the code of conduct.

5.  Promoting and providing anti-corruption training and advice

  • The institution should require (where it has the power to make such requirement) or encourage the inclusion of anti-corruption training as part of university and technical college courses, professional qualification, and continuing professional development requirements.
  • The institution should provide anti-corruption training to its own members and employees or should require its members and employees to undertake appropriate anti-corruption training provided by suitable third-party providers.
  • The anti-corruption training should increase the awareness of all trainees as to:
    • the existence of corruption and its consequences
    • the circumstances where corruption may occur
    • how corruption can be avoided, prevented and reported
    • what to do if confronted with corruption.
  • In relation to the training of the institution’s members and employees:
    • The training should explain the institution’s anti-corruption code of conduct (see 4) and what to do if they suspect that the anti-corruption code of conduct has been or is about to be breached (see 6).
    • The training could be provided by in-person workshops or by on-line methods.
    • Short and simple training modules could be provided to those persons who are only likely to encounter a low risk of corruption in their business, profession, or employment.  More comprehensive training should be provided to those persons who are likely to encounter a more than low risk of corruption (for example, contract managers, procurement and sales personnel).
  • The institution should establish and publicise a mechanism under which its members and employees can seek reasonable and free advice on:
    • what to do if they:
      • are faced with a potentially corrupt situation
      • suspect that a member or employee of the institution has committed or is about to commit a breach of the institution’s anti-corruption code of conduct
    • how and when to report such matters.

6.  Dealing with suspected breaches of the anti-corruption code of conduct

  • Imposing a reporting obligation on members and employees:  The institution should, in its anti-corruption code of conduct (see 4), require its members and employees to make a report in accordance with the institution’s reporting procedures if they suspect that a member or employee of the institution has committed or is about to commit a breach of the institution’s anti-corruption code of conduct.  It should allow an exception to this obligation only where a person fears for her/his safety, or for the safety of another person, if they make such a report.
  • Encouraging the public to report:  The institution should, on its website, encourage members of the public to make a report in accordance with the institution’s reporting procedures if they suspect that a member or employee of the institution has committed or is about to commit a breach of the institution’s anti-corruption code of conduct.  It should also caution members of the public that they should consider not making a report where they fear for their safety, or for the safety of another person, if they make such a report.
  • Establishing reporting procedures:  The institution should establish reporting procedures which enable its members and employees and members of the public to make such reports to the institution.   In order to help protect reporting persons from possible retaliation, these reporting procedures should:
    • permit confidential and anonymous reporting
    • implement reasonable measures to protect such confidentiality and anonymity
    • advise persons who are considering making a report confidentially or anonymously to be aware of the risk that their identity may be inadvertently or illegally disclosed or may be discovered despite measures taken by the institution to protect confidentiality and anonymity.
  • Establishing investigation procedures:  The institution should establish investigation procedures which enable reports to be investigated by the institution in accordance with a fair and objective process which as far as reasonable ascertains the relevant facts and gives the member or employee against whom the allegation has been made an adequate opportunity to respond.
  • Establishing disciplinary procedures:  The institution should establish disciplinary procedures which provide for a fair and objective disciplinary hearing in relation to reports which have been found to have a reasonable basis. The disciplinary hearing should give the member or employee against whom the allegation has been made an adequate opportunity to present her/his case.  If the disciplinary process establishes that the accused was about to commit or has committed a breach of the anti-corruption code of conduct, then the institution should apply reasonable and proportionate sanctions in relation to the accused.  These sanctions could include, as appropriate:
    • a written reprimand
    • a fine
    • temporary or permanent:
      • suspension or dismissal from membership of the institution
      • suspension or dismissal from any office or employment with the institution.
  • Reporting to the law enforcement authorities:  Where the institution identifies that there are reasonable grounds to suspect that a corruption offence may have been committed by any of its members or employees, it should report its suspicions to the law enforcement authorities.

7.  Restricting membership

  • The institution should refuse to accept as a member any person who has been suspended or dismissed from membership by another professional institution due to a breach of that institution’s anti-corruption code of conduct. This refusal should continue for as long as any suspension period applies, or until the institution is reasonably satisfied that the person has taken effective steps to:
    • remedy as far as possible the consequences of the action which led to the suspension or dismissal
    • avoid a repetition of the action which led to the suspension or dismissal.

8.  Providing transparency:

  • The institution should publish information in an easily accessible location on its public website, so that members and employees of the institution and members of the public are aware of the institution’s anti-corruption stance, requirements and activities.  Such information should include:
    • The institution’s anti-corruption commitments, objectives, and activities (see 1, 2, 3 and 5)
    • The institution’s anti-corruption code of conduct (see 4).
    • The obligation or encouragement to report breaches of the anti-corruption code of conduct, and the institution’s reporting, investigation and disciplinary procedures (see 6).
    • The following information in relation to any decision by the institution which finds that a member or employee has committed or was about to commit a breach of the institution’s anti-corruption code of conduct:
      • the name of the member or employee
      • the decision by the institution
      • the sanction issued against the member or employee.

B:  RECOMMENDED ANTI-CORRUPTION RESOURCES

The following are some recommended resources which professional institutions can use to support them in their anti-corruption programme design and implementation.

Anti-Corruption Code of Conduct:

For a sample anti-corruption code of conduct, see Anti-Corruption Code of Conduct for Professional Institutions.  An institution can adopt this sample code (amended as appropriate) as its code of conduct.   Alternatively, an institution can compare the anti-corruption provisions in its existing code of conduct with the provisions recommended in the sample code, and can adapt its code of conduct as appropriate.

Anti-Corruption Measures:

For anti-corruption measures for government and public and private sector organisations, see the following:

  • The Commonwealth Anti-Corruption Benchmarks which are good practice anti-corruption measures designed to prevent corruption in government and in the public and private sectors. Annex A to the Guidance to the Benchmarks contains a simple anti-corruption programme for private sector organisations which enter into contracts with the public sector over a reasonable value threshold.
  • ISO 37001 which is a certifiable international anti-bribery management standard for organisations in both the public and private sectors.
  • GIACC’s Anti-Corruption Programme – Organisations which provides guidance for both public sector and private sector organisations on implementing such measures.
  • GIACC’s Project Anti-Corruption System which is a certifiable management system designed to assist in the prevention and detection of corruption on infrastructure projects.

Anti-Corruption Training:

For anti-corruption training, see:

  • Guidance on different types of training.
  • GIACC Online Anti-Corruption Training:  Short Module: This Short Module is designed to give a brief overview of corruption and of the importance of avoiding any involvement in corruption.  It takes between 20 to 30 minutes to complete.  A certificate of completion can be printed at the end.  It is free of charge.
  • GIACC Online Anti-Corruption Training:  Comprehensive Module: This Comprehensive Module provides a more detailed training than that provided by the above Short Module.  It takes between one to two hours to complete.  A certificate of completion can be printed at the end.  It is free of charge.

If the institution does not have its own training module for its members and employees, it could require them to take GIACC’s Online Anti-Corruption Training (either the Short Module or Comprehensive Module as appropriate) and provide to the institution a copy of the Certificate of Completion as proof.

Anti-Corruption Action Statement

The World Federation of Engineering Organisations (WFEO) has published an Anti-Corruption Action Statement which recommends anti-corruption actions for professional engineers, professional engineering institutions, governments, project owners, project funders, and companies.  This has been published in two language versions:

Anti-Corruption Forums

The institution could initiate or participate in an anti-corruption forum, which is an informal collaboration between professional institutions, business associations, contractors, consultants, suppliers, and civil society organisations (and possibly government), so as to develop a co-ordinated approach to anti-corruption issues.  (See Anti-Corruption Forums).

C:  GIACC ALLIANCES

GIACC has formed anti-corruption alliances with two international organisations, three regional organisations, and 18 national organisations in 15 countries (See GIACC Alliances). 

Under these alliances, GIACC and the listed organisations agree as follows:

  • To work together in the infrastructure sector to promote the implementation of anti-corruption measures as an integral part of government, corporate and project management.
  • To agree on a case by case basis on projects on which they can co-operate so as to achieve the objective.

These alliances are informal.  No new organisation will be formed, and there will be no resulting legal or contractual obligations.  They are alliances to achieve a common objective for the public good.

Under an alliance, GIACC can provide, free of charge, reasonable advice and support to a professional institution in implementing its anti-corruption programme.

For further information, or if your professional institution is interested in forming an alliance, contact GIACC.

Updated on 7th September 2022

© GIACC