131
Good Practice
Anti-Corruption
Global Compact International Yearbook 2013
message across, and teaching employees
how to act responsibly, to respect the fine
line between prohibited and allowed
behavior, and to recognize this grey area
is another thing completely.
“
To establish compliance processes, struc-
tures, codes of conduct, and to integrate
an effective whistleblowing system nor-
mally outweighs the effort to set up
adequate communicationmeasures. We
need to develop a certain awareness re-
garding the communication toward the
desired target group. Communication is
crucial for the success, acceptance, and
efficiency of the compliance program,”
says Kenan Tur, founder and Executive
Board Member of Business Keeper AG.
Hence, communication on compliance
must be practically-oriented, innova-
tive, and convincing. Only through the
continuous sensitization of employees
regarding the important topic of anti-
corruption and compliance can last-
ing changes be achieved and an overall
consciousness of value-based economic
practices be developed and maintained.
Thus, it is advisable to tackle the corporate
culture, which in turn may necessitate
a change management. Following the
theory of Kurt Lewin, the first step is to
catch freezing. This can be reached, for
example, by offering the clear positioning
of the CEO on the topic of anti-corruption.
Announced in different communication
channels, it emphasizes the relevance of
compliance with the support of the top
management and shows that the written
values are actively pursued. During the
second phase, the moving, new solutions
are generated, new behaviors are tried,
and a change movement is carried out.
At this point, the employees must be ad-
dressed with adequate communication
instruments and be sensitized to these.
The ideal case would entail integrated
thinking, whichmeans that integrity and
compliance are automatically included
as elements of every decision within the
company. Within the context of the last
phase, the refreezing, communication
channels that should be used are defined
in case misconduct is observed. The mani-
fold possibilities include the linemanager,
the compliance team, and a functioning
whistleblowing system that guarantees
confidentiality or even anonymity.
In this context, it is advisable that the
compliance units make use of the spe-
cific competences of the communication
departments. A campaign using joint
forces may be much more effective than
the mere dissemination of compliance
content.
For too long, compliance departments
have disregarded the fact that communi-
cation toward the target group not only
needs to be informative but also convinc-
ing in order to increase consciousness
and encourage acceptance for compli-
ance issues and whistleblowing systems.
Internal communication on compliance
topics must nowadays be practical and
true-to-life. Therefore, compliance and
corporate communication departments
have to align their communication efforts
to close this gap. For globally engaged
enterprises it is advisable to consider
cultural differences– for example, based
on historical incidents in the country –
when launching a whistleblowing system.
In general, a decentralized and cultur-
ally adapted communication is likely to
generate higher acceptance throughout
the stakeholders.
It needs to be considered that compliance
without adequate communication can
lead to the same risks as the nonexistence
of compliance – or even worse. With re-
spect to recent scandals in the corporate
world, one can ask why contraventions
still occur even if extensive compliance
structures have been built. One of the
reasons might be that the potential of
a genuine compliance communication
has not yet been exploited.
Business Keeper AG
Merck’s distinctive Compliance Com-
munication Campaign when introducing
a new Whistleblowing System
Business Keeper AG is located
in Berlin, Germany, and provides
the BKMS® System as a unique
solution to establish a 24 / 7
whistleblowing system in order
to discover contravention and
misconduct at an early stage.
Today, the BKMS® System is used
in more than 196 countries and
regions worldwide and is available
in 52 languages.
Customers of Business Keeper AG
appreciate the certified security
of the application as well as the
fact that only authorized examin-
ers have access to the data. The
postbox functionality, which the
whistleblower can use while
remaining anonymous, bridges the
gap between anonymity and the
dialogue between the examiner
and the whistleblower. Possessing
more than 10 years of experience,
Business Keeper AG is a reliable
and competent compliance part-
ner for companies and organiza-
tions.