I’m the Chairman of a business software consulting group that operates in ten countries. We’re not large – around 100 staff – and we’re a relatively loose association, in that ownership differs from place to place. Policy is arrived at by consensus and operational management is devolved. But in some important respects the buck stops with me. I set the tone and style of the organisation, and, again, with the agreement of my partners, its ethics.

If I were to discover that the group were riddled with corruption and fraud I would resign.

Pigs at the trough

I am no expert in these matters, but these are some thoughts on how ethical standards must be set and maintained, whether an organisation is small or global.

Write them down

We have a management manual. Amongst other things it says:

Corruption is widespread in business, perhaps a little more so in Central and Eastern Europe than in other more mature markets. LLP Group and its agents, however, never pay bribes, neither directly nor indirectly.

This means that we never do business when we believe that decision makers are being covertly induced to express an opinion in our favour, whether that inducement comes from us directly or from any other intermediary.

Why?

• Because it is dangerous. Corruption can damage our business.
• Because it is illegal. Corruption can send us to jail.
• Because it is wrong.

What is ‘covert inducement’?

Decision makers are ‘covertly induced’ when they are unable to declare an inducement to their own organisation.

Examples:

A salesman pays a ‘commission’ to the buyer’s employee which the employee cannot acknowledge within his organization.  This commission may come in the form of money, gifts, holidays, etc.

LLP pays an intermediary (for example, a consultant) who is acting as an advisor to the buyer, but the consultant is unable to declare this income (money, shares, holiday, gifts, whatever).

Failure to observe this code will result in immediate termination. No excuses.

Audit

An organisation must constantly be on the alert and should go looking for corruption.

Style

Senior managers should behave with austerity. Luxury hotels, first class travel, limousines, Michelin-starred restaurants, and other forms of prancing, have no place in business life.

Openness

An organisation must be open to inspection by its staff and by the media, and should publish information by default.

Sanctions 

Wrongdoing must be openly punished.

Responsibility

Managers must take responsibility for the lapses of their subordinates. This encourages vigilance.

FIFA would appear to fail in every respect. Corruption is rife, austerity is anathema, investigations are thwarted, secrecy shrouds its inner workings, sanctions are few, and responsibility is shunned.

And Sepp Blatter is still the President of FIFA. And all we hear from him is blather and bluster.