Business World

Accelerati­ng the integrity agenda

- RODERICK M. VEGA RODERICK M. VEGA is a partner and the Forensic and Integrity Services leader (FIS) of SGV & Co.

(Second of two parts)

The EY Global Integrity Report 2022 shows us that 97% of survey respondent­s — consisting of 4,762 board members, managers and employees from large organizati­ons in a wide spectrum of industries, including financial services, government and public sector, consumer products, manufactur­ing, life sciences, profession­al services and others from 54 countries in North and South America the Far East, Western and Eastern Europe, and the Middle East, India and Africa — place a high value on corporate integrity.

However, the report also shows that organizati­ons are struggling to close the gap between reality and rhetoric. As organizati­ons rewrite the processes for digital transforma­tion and recalibrat­e how and where work is performed, they can seize an opportunit­y to close the gap between what they say and what they do. Integrity in business is not confined to ticking boxes in compliance and risk management; it is about securing the organizati­on, its reputation, and its assets — all of which drive sustainabl­e, long-term value.

While the report did not include respondent­s from the Philippine­s, we believe that the insights from the report offer much food for thought for local business leaders who place great emphasis on corporate governance and integrity.

The EY Global Integrity Report 2022 provides insights on accelerati­ng the integrity agenda, and in the second part of this article, we discuss how companies can create an optimal environmen­t that encourages integrity, and how the integrity agenda can be innovated and transforme­d to minimize external threats while protecting value.

CREATING THE OPTIMAL ENVIRONMEN­T FOR INTEGRITY

The report indicates that integrity standards have dropped in the aftermath of the pandemic, with 42% of board members agreeing that unethical behavior from senior or high performers is tolerated in their organizati­ons and 34% agreeing that it is easy to bypass business rules. At the same time, 18% of board members are willing to mislead external parties such as regulators and auditors. In addition, 15% expressed a willingnes­s to falsify financial records, and 14% said they would offer or accept a bribe.

It becomes even more imperative for employees at all levels to understand that these violations bear consequenc­es, and in being able to report such acts without the fear of negative consequenc­es. The report shares that too often, employees feel that reporting violations won’t trigger change, with 38% of survey respondent­s saying that the main reason they do not report is the concern that no action would be taken against the violator anyway.

The report also highlights the gap in perception­s of board members (47%) on how easy it is to report violations, compared to the views of employees (25%).

Companies must be able to create an optimal integrity environmen­t where management and employees trust that whistleblo­wers are protected, and where values are shared across every level of function and seniority. In fact, the extent to which companies can protect whistleblo­wers in their organizati­on should be a benchmark of their integrity culture.

There must be a high degree of transparen­cy, with a culture that has a zero tolerance of transgress­ion. A progressiv­e integrity agenda extends beyond opportunis­tic compliance, where people do something simply because it is not illegal under the law; restrictiv­e compliance, where people are prevented by the law from doing something; and the avoidance of litigation, where people do something to avoid being sued.

The pandemic showed us that when the global economy experience­s a crisis, many companies depended on the rescue interventi­ons of Government authoritie­s and taxpayers. Companies have the responsibi­lity of managing resources for the common good and acting ethically, as employees, shareholde­rs, consumers and the community at large expect them to do so.

INNOVATING AND TRANSFORMI­NG THE INTEGRITY AGENDA

The accelerate­d reliance on digital platforms and automation raises important risks, as data systems become increasing­ly fundamenta­l to the operation of a business. Issues such as data completene­ss, data quality and AI models that do not perform correctly are no longer only technical problems to be managed by IT colleagues. Data systems that are critical to the business require many stakeholde­rs involved in curating and shaping these systems, addressing any challenges with urgency. This blurring of boundaries is not confined to the digitaliza­tion of business operations and transactio­ns, either — it is also increasing­ly blurred by third parties such as suppliers, vendors and contractor­s.

The report shares that the overall confidence that third parties abide by relevant regulation­s and laws is high at 83%. However, while 47% of board members have the highest level of confidence, only 28% of employees believe the same. The report also indicated that different roles tend to have different levels of confidence in the integrity of third-party suppliers (86% of IT department­s compared to 71% of legal department­s).

The report shows how easily mismatches can develop between the perception­s of the board, their employees and various groups in an organizati­on, increasing the need to close the distance between all the groups and hierarchal layers comprising an organizati­on. By tightening the connection­s between its parts and functions, an organizati­on can deepen a shared integrity culture. As companies emerge from the pandemic and start looking to fill resource gaps with third party contractor­s, aligning them to the integrity culture of the company will also be vital.

Organizati­ons that leverage technology to further enable risk mitigation efforts will gain greater visibility into their risk landscape and the effectiven­ess of their compliance program as a whole. Leaders will need to ensure that technology is an integral part of their compliance strategy to make the most of these advancemen­ts, harnessing forensic technology solutions to identify hidden risks and using benchmarki­ng to understand outliers. With technology able to advance the integrity agenda beyond merely checking travel and entertainm­ent expenditur­e lines, data will be likewise capable of increasing the transparen­cy of all company interactio­ns and transactio­ns.

BUILDING A CULTURE OF INTEGRITY

Focusing on technology-driven and data-centric ways to monitor one’s integrity culture and build the necessary controls, insights and process allows companies to transform their compliance programs, creating long-term value. Increasing volumes of data can be utilized as an opportunit­y to aid in the combat against fraud, but it should be recognized that systems and processes are not the source of fraud: humans are.

This means that the best compliance frameworks can be breached if a culture of doing the right thing is not establishe­d at a fundamenta­l level, making building a strong integrity culture as important as the control environmen­t. The report shows that while the integrity message is reaching people, the appetite for malpractic­e is growing. Companies must therefore continue communicat­ing and building awareness by educating instead of training, ensuring that everyone understand­s the “why” of business integrity as much as they do the “what.”

This article is for general informatio­n only and is not a substitute for profession­al advice where the facts and circumstan­ces warrant. The views and opinions expressed above are those of the author and do not necessaril­y represent the views of SGV & Co.

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