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Institutional Integrity ManagementHong Kong Experience
Tony Kwok, SBS, IDS, JPHon Fellow & Adjunct Professor HKU
UN Anti-corruption Expert GroupVisiting Lecturer, IACAVisiting Expert UNAFEI
Regional Coordinator, IAACA Visiting Professor, PRC National Prosecutors CollegeAnti-corruption Advisor to Philippines & Mongolia
Former Deputy Commissioner, ICAC HK
Food for Thought
How much time do I give to maintaining staff integrity?
Food for Thought
What kind of example am I setting in my personal conduct?
Food for Thought
Do I care about conflict of interest?
Food for Thought
Do I exercise effective internal control?
Food for Thought
Do I have an effective system to detect early sign of corruption:
Food for Thought
Do I encourage or discourage whistle blower?
Food for Thought
Do I believe in “Don’t wash your dirty linen in public?
Food for Thought
Do I develop a set of best practice for corruption prevention?
Food for Thought
Do I have an anti-corruption Action Plan?
Every Institution, Government or Private,
should take up Responsibility of Cleaning their Own Houses
Case Study – Hong Kong Police
Squash Development & Corporate Governance
Tony Kwok, SBS, IDS, JPHon Advisor &Former Chairman of Executive CommitteeHong Kong Squash
PILLAR I
EthicalLeadership
PILLAR II
Staff Integrity
PILLAR IV
Monitoring &
Deterrence
PILLAR III
Systems Integrity
Institutional Integrity
Ethic Leadership
1. Tone from the top – zero tolerance
2. Executive Committee to formulate ethic policy, integrity strategy and action plan
3. Declaration system for conflict of interest
PILLAR I
EthicalLeadership
PILLAR II
Staff Integrity
PILLAR IV
Monitoring and
Deterrence
PILLAR III
Systems Integrity
Institutional Integrity
Staff Integrity
1.Tailor made Code of Ethics for staff, players, coaches
2.Integrity vetting
3.staff ethics training
4.Healthy life style
5.Staff appraisal
PILLAR I
EthicalLeadership
PILLAR II
Staff Integrity
PILLAR IV
Monitoring and
Deterrence
PILLAR III
Systems Integrity
Institutional Integrity
System Integrity1) Risk Management2) Proper Accounting 3) Procurement4) Anti corruption Clause in contracts5) Players selection 6) Coaching
PILLAR I
EthicalLeadership
PILLAR II
Staff Integrity
PILLAR IV
Monitoring and
Deterrence
PILLAR III
Systems Integrity
Institutional Integrity
Monitoring & Deterrence
1) External auditors2) Public complaint system3) Protection of whistle blowers
4) Independent Discipline Committee
ICAC Integrity System
• Reasonable pay• Internal Investigation Unit – report to the top• Fair & transparent recruitment• Integrity checking• Staff ethical training• Strict disciplinary regulation：
– Declaration system– Zero tolerance
• Internal & public complaint system• Independent monitoring committee• Internal audit & risk assessment team
Hong Kong Practice Government
• Designated Ethic Officer in every government departments
• Code of Ethics for Civil Servants• Corruption Prevention Handbook for
Managers• Training/workshops• Departmental integrity committee
Hong Kong Practice Business Sector
• Ethic Development Centre• Corruption Prevention Advisory Service• Best Practices Guides• Training Packages for specific sectors,
eg 500 managers in public listed companies
• Self assessment toolkits• HKU Certificate Course in IIO
Certified Institutional Integrity Officer (CIO)
Curriculum
Tony Kwok, SBS, IDSAdjunct Professor & Course Director, HKU
UN Anti-corruption Expert GroupVisiting Lecturer, IACAVisiting Expert UNAFEI
Regional Coordinator, IAACA Visiting Professor, PRC National Prosecutors CollegeAnti-corruption Advisor to Philippines & Mongolia
Former Deputy Commissioner, ICAC HK
Anti Corruption Studies
• Postgraduate Certificate in Corruption Studies (3 weeks, for anti corruption professionals)
• Senior Executive Certificate in Institutional Integrity Management (9 days – for IIO)
Senior Executive Certificate in Institutional Integrity Management
Aims & Objectives
To equip participant with professional knowledge & skill for strengthening the institutional integrity profile of their institution, and hence enhance their capabilities to safeguard their institutions against corruption & fraud
Senior Executive Certificate in Institutional Integrity Management
Upon completion, the participants will be able to :1. Formulate & manage institutional ethic policy & staff
code of ethics2. Formulate, manage & review annual integrity action
plan3. Conduct staff integrity vetting4. Organize staff ethics training & development5. Expertise in risk management6. Establish complaint system & internal monitoring &
investigation on corruption & fraud
Senior Executive Certificate in Institutional Integrity Management
Three modules (3 days each)
1. Institutional Framework2. Corruption Prevention & Education3. Detection & investigation of corrupt
practices & fraud
Senior Executive Certificate in Institutional Integrity Management
1. Institutional Framework• Theories on corruption – definitions,
types, causes & effects, psychology of corrupt behaviours, cultural diversity
• Legal framework – legislations on corruption, fraud, money laundering, conflict of interest
• Strategic Planning workshop
Senior Executive Certificate in Institutional Integrity Management
2. Corruption Prevention & Education• Corruption prevention measures in
procurement, public services delivery, HRM etc.
• Staff code of ethics• Corporate governance• Community education• Partnership with civil societies• Case study – HK Police, World Bank
Senior Executive Certificate in Institutional Integrity Management
3. Detection & Investigation• Complaint system• Protection of whistleblowers• Basic investigation skill• Detection & internal audit• Fraud, money laundering, asset tracing• Writing an investigation report• Case studies
Senior Executive Certificate in Institutional Integrity Management
Assessment - based on an individual project report (2500-3000 words)
A study of corruption & integrity profile in an organization, covering
• Diagnose the current situation• Analyze the causes of corrupt/fraud and
opportunities• Assess the effectiveness adopted• Make recommendation for improvement
Institutional Integrity Structure
• Institutional Integrity Steering Committee
• Institutional Integrity Annual Action Plan
• Institutional Integrity Officer (IIO)
Role of IIO• Provide professional advice to the Steering
Committee• Assist in the formulation of annual action plan• Coordinate & monitor the implementation of
the Action Plan• Progress report to Steering Committee• Provide in house training• Manage an internal complaint system• Staff integrity vetting• Partnership with anti corruption agency &
others
IIO Scheme• Selection – integrity vetting• Two level training• Training for members of steering
committee• Professional training course for IIO
– Curriculum– Assessment
• Advisory Board• Governing & Accreditation Board• Role of ACA
CIO Governing Board
• Define the role of CIO • Accreditation• Registrate & de-registrate CIO• Standardize content of training course• Approve educational institutions to
conduct CIO courses
Conclusion 15 Do-able in a company
For Employers/Senior Management 1. Tone at the top & led by example2. Staff Code of Conduct 3. Conflict of interest management 4. Regular risk assessment5. Sound management and control system6. Effective Staff communication & training7. Enforce compliance & discipline
Conclusion 15 Do-able in a company
For Managers and Supervisors
8. Implement proper procedures and practices
9. Proper control & supervision10. Provide guidance to staff
Conclusion 15 Do-able in a company
For Staff /All11. Know the legal & ethical requirement12. Observe the company rules and code of
conduct13. Stay vigilant to all corruption risks 14. Seek advice/direction from management
in case of doubt.15. Report any suspected malpractices
