As a teaching guide I developed in 2000 the following framework of questions that should be asked at board and internal auditing levels in all organizations. Can you answer these for your organization?

Is your organization’s code of conduct:

– required by your regulators and how?

– led from the top – by style and values?

– embedded in all strategies, plans and operations?

– seen in all structures and systems?

– communicated internally to everyone – staff and visitors?

– communicated externally to all stakeholders?

– known across all supply chains?

– included in all review processes?

– independently monitored?

Does it:

– create/reduce wealth?

– improve/reduce the quality of performance?

– increase/decrease the efficiency and effectiveness of all staff?

– increase/decrease customers’ satisfaction?

– improve/lower the organization’s reputation in society?

– increase/decrease competitive edge?
– consider/ignore all stakeholders’ needs?
– encourage/discourage good behaviour After answering these questions replace ‘conduct’ with ‘fight against crime’ and answer the questions again.
Do you have:
– a formal and published code of conduct?
– a formal fraud policy?
– a formal ant-corruption policy?
– a formal security policy for all your resources, material and people?
– a procedure for dealing with all irregularities?
– a whistleblowing procedure?
– practical ethics training for all your staff?
– environmental management policies, audits and reports?
– environmental, social and ethical accounting and audits?
Satisfactory answers to all these questions, benchmarked against the guidance in this chapter, can reveal many weaknesses in an organization’s attitude to fighting crime at all levels. You may even add other questions appropriate for your organization!