Standards Pioneers Program6° Session
14th November 2017
From theory to practice: Why and how to disclose information on anti-corruption using the GRI Economic Topic-specific Standards?
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Standards Pioneers
Presenters
Francesca PalamidessiSr Coordinator Corporate & Stakeholder Engagement GRI
Rory DonaldsonBusiness Integrity Programme Manager, Transparency International UK
#GOLDCommunity
Veronica Wachong CastroCoordinator StandardsGRI
Fausto MantovaniGlobal Manager on risk and complianceVotorantim Cimentos;
Alexandre TakanoEnvironmental ConsultantVotorantim Cimentos
Today’s agenda
Agenda:Tuesday 14th November 16.30 CET
Presenter
IntroductionFrancesca Palamidessi,Sr. Coordinator Corporate and Stakeholder Engagement, GRI
Anti-Corruption and sustainability reporting
Rory Donaldson, Business Integrity Programme Manager, Transparency UK
Reporting on Anti-Corruption:case study
Fausto Mantovani,Global Manager on risk and compliance,Alexandre Takano, Environmental Consultant,Votorantim Cimentos
Q&AThe Economic Topic-specific Standards: how to disclose information on anti-corruption using the GRI Standards?
Veronica Wachong Castro, Coordinator Standards,GRI
Q&A
Conclusion
Francesca Palamidessi,Sr. Coordinator Corporate and Stakeholder Engagement, GRI
Anti-corruption reporting
Rory DonaldsonProgramme Manager, Business Integrity Programme
www.transparency.org.uk
Transparency International
Transparency International’s Approach:• Zero tolerance• Corruption has victims• Fighting corruption often requires collective action to achieve
systemic change
Founded in 1993Chapters in over 100 countriesSpecialist anti-corruption NGO
Contents• Anti-corruption reporting – what is it and why is it important? • Reporting on anti-bribery programme• Organisational transparency • Country-by-country reporting • Political engagement
www.transparency.org.uk
Anti-corruption reporting – what is it and why is it important?
www.transparency.org.uk
Reporting on the anti-bribery programme
www.transparency.org.uk
Anti-bribery policy - GSK
https://www.gsk.com/media/2976/anti-bribery-and-corruption-policy-v11.pdf
Organisational transparency
www.transparency.org.uk
Organisational Transparency - Lloyds
Lloyds annual report, 293 onwardshttp://www.lloydsbankinggroup.com/globalassets/documents/investors/2016/2016_lbg_annual_report_v2.pdf
Country-by-country reporting
www.transparency.org.uk
Country by country reporting - Vodafone
http://www.vodafone.com/content/index/media/vodafone-group-releases/2017/vodafone-cbc-taxation.html#
Political engagement
https://www.centrica.com/sites/default/files/about_us_-_our_policies/centrica_policy_political_involvement.pdf
Political engagement - Centrica
https://www.centrica.com/sites/default/files/about_us_-_our_policies/centrica_policy_political_involvement.pdf
transparency.org.uk
BUSINESS INTEGRITY FORUM
www.transparency.org.uk
CORPORATE BENCHMARK
www.antibriberyguidance.org
www.transparency.org.uk
Standard PioneersAnti Corruption
November 14th
NorthAmerica*
35%*
A global building materials company
Canada
United States
Morocco
Chile
Bolivia
Peru
Argentina
Brazil
Spain
TunisiaTurkey
China
India
Uruguay
*Representation of each region by EBITDA based on the result of the 20161 In terms of installed capacity, not considering Chinese companies. 2 Employees in Brazil, Uruguay, Bolivia, Canada, USA, Spain, Turkey, Morocco, Tunisia, India and China.3 Does not include plants and capacity of units which results are not consolidated on our balance sheet.
1st in Brazil6th worldwide1
Operating in 14 countries
More than 13,000 employees 2
37 cement plants 3
21 grinding mills 3
249 concrete plants 3
64 aggregates plants 3
12 mortar plants 3
Annual installed cement
capacity of 57,5 M tons 3
Brazil
40%*
Europe,Africa
and Asia*
23%*
Latam* (Bolivia and Uruguay)
1%*
Complete Product PortfolioGlobal Operations
Cement Concrete Aggregates Mortars(Mortar, Lime, Agricultural
Chemicals & White Cement)
One of the highest degrees of vertical integration in the industry
Votorantim Values
Striving for sustainable growth and value generation
SOLIDNESS
Working responsibly and transparently
ETHICS
RESPECT Respect for people and willingness to learn
Growing with courage to do, innovate and act
ENTREPRENEURSHIP
Together we are strongerUNITY
Votorantim CimentosThe building materials company committed to
creating customer value through excellence
Sustainability for us
“For us, sustainability means pursuing our growth ambitions while taking into
account society’s present and future needs, providing our customers with eco-efficient building materials and
services, offering our employees a safe, healthy and inspiring work place, as
well as driving local community development.”
Santa Helena Cement Plant
Sustainability StrategyOur Strategic Sustainability Plan is based on four
pillars
Safety
Ethics andcompliance
Eco-efficiency& innovation
CommunityEngagement
Safety first!
We comply fully with laws and regulations wherever we do business
We promote eco-efficiency through the use of innovative products and practices
We develop community relations and promote dialogue to perpetuate the Votorantim legacy
Votorantim Cimentos’ Reporting History
CSI contentdisclosed onVC Website
2005 - 2015 Since 2010
VC Integrated Report 2013
GRI G4+ UNGC+IIRC+CSI+ Third party
assurance
VC Integrated Report 2014/2015
+ ‘Form. Ref.’+ Earnings Release
GRI G4+ UNGC+IIRC+CSI+ Thir party
assurance+
Short Version
Integrated Report VID GRI +UNGCThird party assurance
VC Integrated Report 2016
Evaluated as the best overall score in the Reporting
Matters publication (WBCSD)
• Impact Matrix• External
readers• SDGs
Sustainability StrategyOur Strategic Sustainability Plan is based on four
pillars
Safety
Ethics andcompliance
Eco-efficiency& innovation
CommunityEngagement
Safety first!
We comply fully with laws and regulations wherever we do business
We promote eco-efficiency through the use of innovative products and practices
We develop community relations and promote dialogue to perpetuate the Votorantim legacy
Compliance Integrity
To comply with the applicable laws and regulations, as
well as policies and standards set by the
company’s business and activities.
Do what is right, even when it is not the most
convenient or nobody is monitoring.
It means follow the company’s Values, Beliefs and Code
of Conduct.
The word Compliance comes from the verb "to comply", which means "to accomplish".
FUNCTIONS INSTRUMENTS
Policys andProcedures
Critical DocumentsManagement
Law and RegulationResearch
Education and TrainingCulture
OmbudsmanCommunication Lines
Obligations assessment systemMonitoring
Disciplinary Guidelines and corrective actions
Disciplinary Measures
Code of Conduct BeliefsValues
PILLARS
Law
san
dR
egul
atio
ns
Lice
nses
, Per
mits
and
Cer
tific
ates
Con
trac
tsan
dAg
reem
ents
Exte
rnal
Rep
orts
Antit
rust
Loss
Pre
vent
ion
Anti-
corr
uptio
n
Legal and RegulatoryFramework
The Pillars of the Compliance Program
Code of Conduct is part ofVotorantim DNA
the document that states our Values and way of doing business worldwide.
A key pillar of Compliance is the Anti-Corruption Program, which has a broad scope and requires a joint effort of many departments
Joint initiatives with Legal: Anti-Corruption communication campaign and Rollout of online training: Antitrust and Anti-Corruption
The Anti-corruption Program is a priority for VC and has been led by the Compliance and Legal departments, who carried out various actions since 2014.
Anti - Corruption Compliance Program
It is a no return way
Competitive advantage
Prevents risks and reduces penalties
Non-compliance is expensive
Attracts and provides security to investors
It is a Value
Protects the company…
Conflicts of Interest. Antitrust. Receipt and offer of gifts and
gratuities. Entertainment and hospitality. Anticorruption. Facilitation payments. Political contributions and
sponsorships. Social responsibility and social
contributions.
Compliance Global Guidelines
Compliance Anti - Corruption Global Strategy
Canada
United
States
Morocco
Chile
Bolivia
Peru
Argentina
Brazil
Spain
TunisiaTurkey
China
India
Uruguay
Brazilian Headquarter2 offices worldwide
Operating in the same way in14 countries
More than 13,000 employees with same information
STRATEGIC PLAN
COMPLIANCE MANAGEMEN
T
Evaluation of Strategic Plan
Analysis of Operational
Risks
Risk Assessment with the Iniatives
Owners
Risk Categories/Areas
Market
Raw Materials
Infrastructure
Supply Chain
Labour Relations
Commercial
Votorantim Anti- Corruption Program follows the AS 3806-2006 guidelines that establishes the compliance management process:
Mapping the Regulatory Framework of the company
Identification of the main obligations
1. Understand the Legal and RegulatoryEnvironment
2. Create and Maintain the RequirementsRegister and the Obligations Register
3. Compliance Risk Assessment
4. Manage Obligations
5. Communication & Reporting
Define and implement the maincompliance processes
Define a communication plan
Develop communication and training activities
6. Monitor and
Evaluation
Report compliance issues andaccomplishments
CriteriaA globalCompliance Methodology
We focus our efforts to define proper procedures to mitigate our critical risks.
• Penalties to employees;
• Negative impacts on company’s Reputation;
• Warnings;
• Administrative sanctions;
• Legal lawsuits;
• Fines;
• Temporary suspension of activities;
• Withdrawal of operation licenses;
• Employees arrest and fining;
Communication: Non-compliance to the laws in general triggers serious consequences
Protects our company’s ValuesImpacts our financial performance
• Misconducts, infringement of policies and procedures;
• Non-compliance of laws and regulations;
• Media questioning;
• Social pressure;
Risks
Guidelines for Interacting with Government Officials
2015:
2016:
Anticorruption risk assessment conducted in VCBR identified the need to improve guidance for employeeswho interact with government officials.
Legal & Government Affairs and Compliance departments define proper procedures for working with government officials and wrote a handbook to explain them.
• 6 areas mapped: Sales, Procurement, R&D, Logistics, Ports, Ready-Mix.
• 60 professionals interviewed;
• 50 activities w/ direct and/or indirect interaction;
• 67 govt. agencies;
• 138 process walkthroughs; • ~80 recommendations to
increase anticorruption awareness and controls.
• Guidelines and procedures stablished;
• Handbook developed and launched to all employees;
• Internal Communication plan deployed
• 8 live training sessions;
• 107 key employees trained, including executives and operations’ leaders
Anticorruption Risk Assessment
Risk mitigation initiatives
2015/2016 2017
Compliance and Government Affairs initiative held in Brazil to prevent corruption risks
Next Steps
Monitoring of the effectiveness through Compliance Processes and Controls standardized globally
Deployment of Main Guidelines through Policies and Procedures
Building of a Global Compliance Culture and design of the Critical Guidelines
Structuring of the Global Compliance Department and Communication of the Program.
2014 -15
Maturity EvolutionDeploymentFoundation DefinitionStructure and Diagnosis
2016 2017 2018+
Building a Robust Program
Anti-corruption ProgramCommunication & Training
Compliance Monitoring
Advantages/benefits of reporting (Votorantim Cimentos particular case)
- Helped the company to improve the internal culture of sustainability
- Internal tool for improvement and official information consultancy
- Only non-financial public report of the Company available to our investors
Advantages of implementing the new GRI Standards
- Modular structure- Less aggressive transitions- Clearer guidance- Changes made reports from different
markets more comparable.
ConclusionGRI Standards
Standards Pioneer Program6th Session
14th Nov2017
Topic-Specific Standards Anti-corruption
#GOLDCommunity
42
The modular set of GRI Standards
43
How to use the GRI Standards?
44
Inside a topic-specific Standard: GRI 205
Management approach disclosures (references GRI 103)
Overview of disclosures in the Standard: * Management approach disclosures * 3 Disclosures
Management approach disclosures for GRI 205 includes additional Recommendations
45
Inside a topic-specific Standard: GRI 205
Each disclosure has a unique identifier, based on the Standard number (e.g., Disclosure 301-1)
Each disclosure is in a box
Each disclosure can include additional requirements, recommendations, and/or guidance –these will be directly below each disclosure
46
GRI 205 Anti-corruption
Corruption ‘abuse of entrusted power for private gain’, which can be instigated by individuals or organizations (1)
‘…corruption is understood to include practices such as bribery, facilitation payments, fraud, extortion, collusion, and money laundering; the offer or receipt of gifts, loans, fees, rewards, or other advantages as an inducement to do something that is dishonest, illegal, or represents a breach of trust. It can also include practices such as embezzlement, trading in influence, abuse of function, illicit enrichment, concealment, and obstructing justice.’ (2)
(1) GRI Glossary of terms. p 6(2) GRI 205 Anti-corruption. Introduction D. Background context. p 4
47
GRI 205 Anti-corruption
• Management approach disclosures
• Disclosure 205-1 Operations assessed for risks related to corruption
• Disclosure 205-2 Communication and training about anti-corruption policies and procedures
• Disclosure 205-3 Confirmed incidents of corruption and actions taken
Disclosures
48
Disclosure 205-1 Operations assessed for risks related to corruption
The reporting organization shall report the following information:
a. Total number and percentage of operations assessed for risks related to corruption.
b. Significant risks related to corruption identified through the risk assessment.
Reporting requirements
49
Disclosure 205-2Communication and training about anti-corruption policies and procedures
The reporting organization shall report the following information:
a. Total number and percentage of governance body members that the organization’s anti-corruption policies and procedures have been communicated to, broken down by region.
b. Total number and percentage of employees that the organization’s anti-corruption policies and procedures have been communicated to, broken down by employee category and region.
c. Total number and percentage of business partners that the organization’s anti-corruption policies and procedures have been communicated to, broken down by type of business partner and region. Describe if the organization’s anti-corruption policies and procedures have been communicated to any other persons or organizations.
Reporting requirements
50
Disclosure 205-2Communication and training about anti-corruption policies and procedures (cont.)
The reporting organization shall report the following information:
d. Total number and percentage of governance body members that have received training on anti-corruption, broken down by region.
e. Total number and percentage of employees that have received training on anti-corruption, broken down by employee category and region.
Reporting requirements
51
Disclosure 205-3Confirmed incidents of corruption and actions taken
The reporting organization shall report the following information:
a. Total number and nature of confirmed incidents of corruption.
b. Total number of confirmed incidents in which employees were dismissed or disciplined for corruption.
c. Total number of confirmed incidents when contracts with business partners were terminated or not renewed due to violations related to corruption.
d. Public legal cases regarding corruption brought against the organization or its employees during the reporting period and the outcomes of such cases.
Reporting requirements
How are Standards reviewed?
• Based on stakeholder feedback and reporting developments, the GSSB initiates the review and update of a GRI Standard;
• A multi-stakeholder Project Working Group or a Technical Committee of experts in the field is selected by the GSSB;
• Through a series of meetings, the experts work together to update the revised Standard;
• The draft Standard is exposed for a Public Comment Period, after which the experts revise the draft based on public comments and issue final recommendations;
• The GSSB discusses and approves final recommendations.
Contacts
Corporate & Stakeholders Team For resources, registrations or additional [email protected]
Standards Team For technical enquiries or specific questions on the [email protected]
“The new GRI Standards help us integrate sustainability into our client’s value reporting.” (Petranix)
Thank you
www.globalreporting.org
GRIBarbara Strozzilaan 3361083 HN Amsterdam
The Netherlands
Amsterdam | New York | Beijing | Sydney | New Delhi | Johannesburg | Bogota | São Paulo
Conclusion
Last 2017 Standards Pioneer’ session
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Guest Speakers: Tim Mohin, Chief Executive, GRIKirsten Margrethe Hovi, VP & Head of Extra-Financial Reporting Norsk Hydro ASA
Tuesday 28th November
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Contacts
Corporate & Stakeholders Team For resources, registrations or additional [email protected]
Standards Team For technical enquiries or specific questions on the [email protected]
#GOLDCommunity
Thank you
www.globalreporting.org
GRIBarbara Strozzilaan 3361083 HN Amsterdam
The Netherlands
Amsterdam | New York | Beijing | Sydney | New Delhi | Johannesburg | Bogota | São Paulo
