2014-15 Canada-China Business Forum Magazine - Page 82

INTERNAL CORPORATE ENGAGEMENT Engaging internal staff through CSR-related practices and initiatives can boost morale and improve staff retention. There is growing expectation that foreign enterprises would support local charities and disaster relief initiatives. However, internal CSR initiatives need to be localized because ideas exported from Canadian headquarters may be inappropriate. For instance, some human resources managers may view the introduction of flexible working schedules as losing control over productivity. Certain teambuilding activities, such as pie-throwing contests may cause managers to lose face in front of their teams. • Do you know what internal CSR initiatives are expected of you? • What are the goals of internal CSR initiatives and corporate engagement in China? Retention of staff? Boosting morale? Boosting productivity? Capacity building? Meeting shareholder or stakeholder expectations? Improving government relations? • How can you ensure buy-in, localization, ownership and empowerment? • Are you communicating the objectives of CSR initiatives clearly to your Chinabased managers and staff? • CORRUPTION & GIFT-GIVING Tips: Involve Stakeholders Establish a local committee with key representatives from the human resources department. Determine if it is appropriate to allow other key staff to volunteer on this committee. Explain clearly the goals of internal CSR initiatives in Canada or elsewhere, and explain how various initiatives in Canada have helped achieve these goals. Determine with input from committee members what the CSR goals are for China operations and then determine which programs will meet these goals. Establish a budget, assign roles and responsibilities, and communicate progress to all staff. Non-Governmental Organizations If an initiative involves a local non-governmental organization (NGO), be very careful that the Chinese authorities properly sanction it. Also be careful that it is not associated with a personal special interest of an official, as this may be construed as bribery. Preventing and detecting bribery is increasingly important in light of regulatory changes over the past decade, which has made corruption and bribery of foreign government officials a criminal offence in Canada as well as in other jurisdictions such as the U.S. and the U.K. These countries are aggressively asserting jurisdiction over the foreign operations and business practices of companies operating in their respective jurisdictions. Violation of anti-corruption laws in Canada, U.S. and U.K. can result in significant fines and imprisonment for individuals involved. In China, corruption can carry the death penalty. Education & Professional Development Ideas to consider: recycling, carpooling, flextime, volunteerism, community service, disaster relief, education (including English lessons), health and wellness, raising CSR awareness. Educational opportunities for staff or their families are highly valued. Tips: Develop an Anti-Bribery Compliance Program A company should have an ethics policy, code of conduct or specific anti-bribery policy that clearly spells out that both giving and receiving bribes are illegal and forbidden. The policy must spell out who is responsible and accountable for the compliance systems and periodic review and updating of the policy. The compliance program should include provisions for staff training on the appointment of the company’s policy, compliance with staff policies and periodic signing off on the policy by all relevant staff. The policy should also address how books and records are to be kept and what to do with regards to reporting violations. As ethical breaches and corrupt activities are, by their nature, very hard to detect, whistleblowing by staff should be encouraged with a clear policy statement that there will be no reprisals against whistleblowers. Do Your Due Diligence Any business partner or supplier who is less than transparent with information will likely be deficient in other areas. Anticorruption due diligence should be conduc ted on all thirdparty business partners and suppliers that interact with government officials or state-owned enterprises on your company’s behalf. Due diligence is required to ensure such parties are reputable and qualified to perform the services they have been retained for and to detect historic or extant corruption issues. Contracts with third-party business partners or suppliers should also contain appropriate anti-corruption representations and warranties. It should be noted that this is very hard to do and specialized firms can be retained to help. The CCBC and the Canadian embassy can provide guidance. Know Your Supply Chain Be suspicious of evasive, incomplete or dismissive answers to questions about behaviour, corruption and bribery. International legislation requires you to be aware of all behaviour throughout your supply chain. COMPLIANCE & LICENCES Business licences in China can be very restrictive and difficult to obtain. It is important to recognize the limitations associated with the very large Restricted Sectors and understand exactly what business practices are allowed under each type of business license you are applying for. Local legal advice is essential during the licencing phase of your business. It is also important to check the licences of your partners and suppliers. Do Your Homework Tips: Useful guidance can be had from Transparency International Canada, their anti-corruption checklist and their workshops to better understand anti-corruption legislation and what it means for your business. Export Development Canada’s anti-corruption quiz and its primers on the subject also provide useful guidance. Conduct Audits Frequently The ability to audit a contractor, supplier or partner at any time is essential. CANADA CHINA FORUM BUSINESS 2014-2015 ccbc.com This informative guide was produced by the CCBC Corporate Social Responsibility Committee. For more information or to learn more about the CCBC CSR Committee, 82 please contact Garrick Ngai, Director of Communications, at garrick@ccbc.com