WBG/KWPF Integrity Compliance Guidance Tool

General Context

General Context
General Context
1. How would you define “compliance” in the business context?
General Context
2. What is the purpose of an integrity compliance program, and why should my company consider investing in one?
General Context
3. Does your company have in place an integrity compliance program?
General Context Q4
4. Is there a focal person within your company who oversees the company’s efforts to prevent corruption and other integrity-related misconduct across departments and in day-to-day operations?

In other words: Is there someone who makes sure that everybody understands the company’s position on integrity compliance and how it affects their daily work?
General Context Q5
5. Does your company have written policies that expressly prohibit the following types of misconduct? Please select all that apply.

Integrity Risk Profile Considerations

Integrity Risk Profile Considerations
Integrity Risk Profile Considerations
1. How many employees work for your company?
Integrity Risk Profile Considerations
2. Does your company conduct business in locations that are generally understood to have high level of corruption?
Integrity Risk Profile Considerations
3. Does your company interact with public officials, governments, international organizations, or multilateral development banks?
Integrity Risk Profile Considerations Q4
4. Does your company engage sales agents or business development consultants?
Integrity Risk Profile Considerations
5. Does your company partner with companies in bidding consortiums or joint venture arrangements?
Integrity Risk Profile Considerations Q6
6. Does your company work in an industry that is generally understood to have high levels of corruption”?
Integrity Risk Profile Considerations Q7
7. Which of these activities are common at your company? Select all that apply:

Integrity Risk Assessment Considerations

Integrity Risk Assessment Considerations
Integrity Risk Assessment Considerations Q3
1. Has your company completed a comprehensive integrity risk assessment?
Integrity Risk Assessment Considerations
2. Does your company have in-house expertise to conduct a comprehensive integrity risk assessment?
Integrity Risk Assessment Considerations
3. Does your company involve management and other relevant personnel in the integrity risk assessment?
Integrity Risk Assessment Considerations Q4
4. Does the company regularly review and update its integrity risk assessment?
Integrity Risk Assessment Considerations Q5
5. Does your company monitor integrity risks through periodic audits and develop corrective action plans in response to audit findings or substantiated misconduct?

Integrity Function Considerations

Integrity Function Considerations
Integrity Function Considerations Q1
1. Does your company have an “integrity function,” i.e., a group of individuals who are responsible for, and dedicated to, the integrity compliance program? (Such individuals often have titles such as Compliance Officer, Ethics Officer, Integrity Officer, etc.)
Integrity Function Considerations Q2
2. To whom does the integrity function report? Select all that apply.

Accessibility, Advice & Guidance Considerations

Accessibility, Advice & Guidance Considerations
Accessibility, Advice & Guidance Considerations Q1
1. Please rate your agreement with the following statement. “I am aware of and understand the integrity compliance policies and procedures that apply to the company I work for, and to my job in particular.”
Accessibility, Advice & Guidance Considerations Q2
2. Please rate your agreement with the following statement. “I know whom to ask for advice and guidance if I have a question about my company’s integrity compliance policies and procedures and would feel comfortable doing so.”

Duty to Report Suspected Misconduct & Whistleblowing Channel Considerations

Duty to Report Suspected Misconduct & Whistleblowing Channel
Duty to Report Suspected Misconduct Q1
1. Does your company require employees to report suspected misconduct or violations of the integrity compliance program, to the extent permissible under applicable law?
Duty to Report Suspected Misconduct Q2
2. What reporting mechanisms are available at your company for employees who wish to report suspected misconduct or violations of the integrity compliance program (i.e., whistleblowing channels)?
Duty to Report Suspected Misconduct Q3
3. At your company, reports of known or suspected misconduct can be submitted to management or the integrity function…. [select all that apply].

Investigation

Investigation & Remediation Procedure Considerations
Investigation & Remediation Procedure Considerations Q1
1. Does your company have a written protocol or procedure for conducting investigations into suspected corruption and related misconduct?
Investigation & Remediation Procedure Considerations Q2
2. At your company, who conducts investigations into suspected misconduct or violations of the integrity compliance program? Please select all that apply.
Investigation & Remediation Procedure Considerations Q3
3. Is there a disciplinary policy for integrity compliance violations at your company?
Investigation & Remediation Procedure Considerations Q4
4. Are you aware of any integrity-related investigations or audits at your company, or any disciplinary actions or other remedial measures taken in response to integrity concerns?

Training & Communication Considerations

Training & Communication Considerations
Training & Communication Considerations Q1
1. How often are employees at your company required to complete training on integrity compliance?
Training & Communication Considerations Q2
2. Apart from training, how does your company communicate matters relating to the integrity compliance program? Select all that apply.
Training & Communication Considerations Q3
3. Is there a culture of integrity compliance within your company?
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