Addressing Corruption in the Project Cargo and Breakbulk Industry
deugro Guide to Mitigation and Management
Corruption is a threat to our business and employees and is counter to our culture. We owe it to our business partners, communities, shareholders, and ourselves to conduct our business with utmost ethics and integrity and to denounce corruption.
To state it simply: paying bribes is completely unacceptable under all deugro standards
What is bribery and corruption?
Bribery is the offering, promising, paying, authorizing payment of, or giving anything of value to a Public Official, an individual or business partner in order to retain or obtain business or secure some other unlawful advantage. Corruption is the misuse of public office or power for private gain or misuse of private power in relation to business outside the realm of government.
Acts of bribery or corruption are designed to influence the individual in the performance of their duty and lead them to act dishonestly.
Examples of Bribery include:
- Payments to an individual to secure a contract from the company they work for.
- Gifting expensive watches
- giving cash or providing other items of value to Public Officials to avoid the customs process
- pass off fake documents
- or smuggle contraband including medicine and armaments into a country.
- Hiring an individual’s son or daughter to retain business with the company they work for.
- Payments from an agent to a Public Official to secure a faster licensing process.
What is a Facilitation Payment?
A Facilitation Payment is a small payment given to a Public Official, usually in cash, to secure the performance of a legitimate, routine government action. It is in often also referred to as “speed money” or “grease money”. For example, giving a Customs Official $50 to speed up the clearance process or to expedite a license or other official documents.
Facilitation payments are strictly prohibited at deugro under any circumstances.
What is a “red flag” and what are some potential “red flags” when it comes to bribery?
A red flag is a set of facts or circumstances that are always investigated before knowing if proceeding is appropriate.
Some potential red flags include:
- A Customs Official requesting a payment to move our shipment to the front of the line.
- Customer or Public Official linking gifts or hospitality to a business benefit.
- A Public Official suggesting receiving payments or donations to resolve a dispute.
- An invoice from a subcontractor or agent includes undefined terms like “additional fees” or “handling fees” or “extra costs” etc. that are not normal or are unsubstantiated.
- Public Official charging fee for service but being unwilling to give a receipt.
- A customer or agent saying a payment is necessary to “do business here”.
- A Public Official saying an extra payment is necessary for them to do their job.
- A dispute with a local regulator suddenly ending without explanation.
Each Branch Manager / Country Manager always ensures that the office for which he/she is responsible implements the necessary steps to prevent bribery and corruption given the risks related to the countries in which they operate.
How deugro tackles corruption?
At deugro, we’ve been expanding our business in freight forwarding and project logistics, and at the heart of everything we do is making sure our stakeholders trust us. This trust is built on our strong ethics and compliance culture. Here’s how we tackle corruption:
01
Policies, Procedures and Training
We have solid policies and procedures to prevent corruption, laid out in our Code of Ethics and Compliance and Anti-Corruption Standard Operating Procedures.
Our Legal and Compliance Team keeps these policies up do date and regularly monitors that the organization follows them.
Our employees get regular training on anti-bribery and anti-corruption through required e-learning courses and face-to-face workshops.
02
Risk Assessment and Due Diligence
We’re proud of our ISO 37001 certification, which shows our commitment to protecting our employees, shareholders, customers, and business partners from bribery risks.
To maintain this certification, we do regular bribery risk assessments and due diligence on our projects and business associates. These assessments help us identify potential risks and put the right processes in place to manage them.
Our due diligence processes help us understand who our business partners are and spot any potential conflicts of interest.
03
Reporting
Our SpeakUp! Tool, accessible at www.deugro-group.com/speakup, is our whistleblowing hotline. It’s open to all our employees and stakeholders, including clients and subcontractors.
We rely on our stakeholders to “SpeakUp!” and report any near-misses, incidents, or concerns, whether they’re related to bribery and corruption or not.
Reports can be made anonymously, and we have a clear process for handling and investigating these reports.
04
Collaboration and Industry Best Practices
Beyond our internal efforts, deugro actively participates in forums and initiatives to promote transparency and fight corruption.
We share best practices and learn from others to continuously improve our anti-corruption strategies.
Being part of compliance networks helps us stay updated on the latest developments and regulatory changes, ensuring our policies and procedures are always up to date.
05
Continuous Improvement and Monitoring
We know that fighting corruption is an ongoing effort that requires constant vigilance.
We regularly review and update our policies, training programs, and risk assessment methods to keep up with new threats and regulatory requirements. Our internal audit team plays a crucial role in monitoring compliance and finding areas for improvement.
By fostering a culture of continuous improvement, we aim to stay ahead of potential risks and maintain the highest standards of integrity in all our operations.
By implementing these measures, deugro not only protects itself from the risks of corruption but also sets a standard for ethical conduct in the project cargo and breakbulk industry. We believe that maintaining a strong compliance culture is key to our long-term success and the trust of our stakeholders.