Integrity handbook by AmCham Philippines

THE INTEGRITY COMPLIANCE HANDBOOK

CONTENTS Introduction: The Integrity Compliance Handbook . . . . . . . . . 1 The Integrity Initiative . . . . . . . . . . . . . . . . . . 2 The Integrity Consortium . . . . . . . . . . . . . . . . 4 Integrity in Philippine Business: Findings from Benchmark Studies . . . . . . . . . . . 8 Integrity Pledge . . . . . . . . . . . . . . . . . . . . . .10 Unified Code of Conduct for Business . . . . . . . 13 The Integrity Compliance Framework . . . . . . . .16 Process Flow for Signatories . . . . . . . . . . . . . 18 Self-Assessment Tool . . . . . . . . . . . . . . . . . . 19 External Validation . . . . . . . . . . . . . . . . . . . .33 Certification . . . . . . . . . . . . . . . . . . . . . . . . 37 Communicating Integrity: Tips and Best Practices . . . . . . . . . . . . . . . . . 38 Progress Map of Integrity Initiativeâ&#x20AC;&#x2122;s Participating Organizations . . . . . . . . . . . . . . 42 Resources . . . . . . . . . . . . . . . . . . . . . . . . . 41 Acknowledgments . . . . . . . . . . . . . . . . . . . 46

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iii

INTRODUCTION:

THE INTEGRITY COMPLIANCE HANDBOOK The Integrity Compliance Handbook is a compendium of key documents and toolkits the Integrity Initiative has used in implementing the project. It aims to make materials on business ethics and control measures accessible to signatories of the Integrity Pledge. The Handbook is a product of over two years of consultations, roundtable discussions and public forums involving business leaders, compliance officers, corporate governance experts, academics, and practitioners from small and medium enterprises to Fortune 500 companies. While the contents of this handbook are designed to be utilized by signatories of the integrity pledge, they can also be used by organizations sharing the Integrity Initiativeâ&#x20AC;&#x2122;s aim of promoting ethical business practices. Those who, in one way or another, contributed to this compendium are acknowledged at the end of the handbook. Needless to say, any errors found in this handbook are the responsibility of the Integrity Initiativeâ&#x20AC;&#x2122;s Project Management Team.

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THE INTEGRITY INITIATIVE The Integrity Initiative is a private sector-led campaign aiming to strengthen ethical standards in business. It aspires for a level playing field where companies that do business with integrity enjoy competitive advantage in both government and private sector transactions. To achieve this goal, market players in the Philippines must adhere to common ethical standards. Through the principle of collective action, the Initiative brings together businesses and industry associations to follow a common roadmap that institutionalizes integrity in all aspects of the business process.

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THE INTEGRITY CONSORTIUM The Makati Business Club (MBC) and the European Chamber of Commerce of the Philippines (ECCP) serve as the Integrity Initiativeâ&#x20AC;&#x2122;s secretariat. The project started in December 2010 after the Philippines received a grant from Siemens (see www.siemens. com/integrity-initiative) to implement Project SHINE. SHINE is a four-year project that sets up an accreditation system for companies that consistently uphold integrity in their business process. Since 2010, MBC and ECCP have been joined by various organizations and industry associations in taking an active role in promoting honesty and transparency in Philippine business. NATIONAL CAPITAL REGION Adboard of the Philippines www.adboard.com.ph

American Chamber of Commerce of the Philippines www.amchamphilippines.com Asian Institute of Management (AIM) www.aim.edu

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Association of Certified Fraud Examiners (ACFE) www.acfe.com Association of Development Financing Institutions in Asia & the Pacific (ADFIAP) www.adfiap.org Australia-New Zealand Chamber of Commerce www.anzcham.com Bankers Institute of the Philippines www.baiphil.org Bishops-Businessmenâ&#x20AC;&#x2122;s Conference for Human Development www.bbc.org.ph British Chamber of Commerce of the Philippines www.britchamphil.org Canadian Chamber of Commerce of the Philippines www.cancham.com.ph Coalition Against Corruption (CAC) www.cac.org.ph Employers Confederation of the Philippines (ECOP) www.ecop.org.ph European Chamber of Commerceof the Philippines (ECCP) www.eccp.com

Federation of Filipino-Chinese Chambers of Commerce & Industry, Inc. (FFCCCII) www.ffcccii.org

People Management Association of the Philippines (PMAP) www.pmap.org.ph

Financial Executives of the Philippines (FINEX) www.finex.org.ph

Philippine Constructors Association (PCA) www.philconstruct.com

Foundation of Society of Fellows of Supply Management www.sofsm.org

Philippine Institute for Supply Management (PISM) www.pism.org

French Chamber of Commerce in the Philippines www.leclub-fcc.org

Philippine Institute of Certified Public Accountants (PICPA) www.picpa.com.ph

German-Philippine Chamber of Commerce www.gpcci.org Good Governance Advocates and Practitioners of the Philippines (GGAPP) www.goodgovernancephilippines.org Institute of Corporate Directors (ICD) www.icdcenter.org/cg Makati Business Club (MBC) www.mbc.com.ph

Philippine Marketing Association (PMA) www.philippinemarketing.net.ph Philippine Society for Training & Development, Inc. (PSTD) www.pstd.org Procurement and Sourcing Institute of Asia (PASIA) www.pasia.org Public Relations Society of the Philippines (PRSP) www.prsociety-philippines. blogspot.com

Management Association of the Philippines (MAP) www.map.com.ph Philippine Chamber of Commerce and Industry (PCCI) www.philippinechamber.com

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LUZON

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Philippine Chamber of Commerce and Industry (PCCI):

VISAYAS

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Association of Negros Producers Bankers Association of Iloilo Bankers Club of Negros Occidental Bohol Assocation of Hotels, Resorts and Restaurants Bohol Bankers Association Bohol Island Tour Guides Association of the Philippines, Inc. ( BITGAP) Bohol Society of Travel Agencies Bosconian International Chamber of Commerce Brotherhood of Christian Businessmen and Professionals (BCBP) â&#x20AC;&#x201C; Iloilo Canadian Chamber of Commerce â&#x20AC;&#x201C; Cebu Cebu Business Club Cebu FAME (Fashion Accessories Manufacturers-Exporters) Cebu Furniture Industries Foundation, Inc. ( CFIF) Cebu-Gifts Toys and Housewares Manufacturers and Exportersâ&#x20AC;&#x2122; Association (Cebu GTH) Cebu-Filipino Chinese Chamber Christian Brethren International Federation of Filipino Chinese Chamber of Commerce and Industry of Panay Filipino Chinese Chamber of Commerce of Iloilo, Inc. Financial Executives of the Philippines (FINEX) â&#x20AC;&#x201C; Cebu Hotel and Restaurant Association of Negros Occidental

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Iloilo Business Club Iloilo City Investment and Promotions Board Iloilo Convention and Visitors Bureau Iloilo CREBA (Chamber of Real Estate Builders Association) Iloilo Dinagyang Foundation Iloilo Multi-Sectoral Group Iloilo SMED Foundation Inc. Ilonggo Producers Association Metro Bacolod Chamber of Commerce National Association of Independent Travel Agencies Panay Organic Producers Association Philippine Chamber of Commerce and Industry (PCCI): t #PIPM $IBNCFS PG $PNNFSDF t $FCV $IBNCFS PG Commerce & Industry t $IBNCFS PG $PNNFSDF & Industry of Iloilo t -FZUF $IBNCFS PG $PNNFSDF & Industry t .BOEVBF $IBNCFS PG $PNNFSDF t .FOEP[B $IBNCFS PG Commerce & Industry t .FUSP #BDPMPE $IBNCFS PG Commerce & Industry t /FHSPT 0DDJEFOUBM $IBNCFS of Commerce & Industry t 3FHJPO 7* t 3FHJPO 7*** Philippines Retailers Association of Iloilo Philippine Red Cross - Iloilo Philippine Institute of Certified Public Accountants (PICPA) - Cebu

MINDANAO Chamber of Real Estate Builders Association (CREBA) â&#x20AC;&#x201C; Davao Chapter Japanese Chamber of Commerce of Mindanao Mindanao Business Council Philippine Chamber of Commerce and Industry (PCCI): t #BTJMBO .JOEBOBP $IBNCFS of Commerce & Industry t $FOUSBM .JOEBOBP $IBNCFS of Commerce & Industry t &BTUFSO .JOEBOBP $IBNCFS of Commerce & Industry t %BWBP $JUZ $IBNCFS PG $PNNFSDF t %JQPMPH $IBNCFS PG Commerce & Industry t (SFBUFS .JETBZBQ $IBNCFS of Commerce & Industry t *TVMBO 4VMUBO ,VEBSBU $IBNCFS of Commerce & Industry t ,BCBDBO $PUBCBUP $IBNCFS of Commerce & Industry t .FUSP $PUBCBUP $IBNCFS PG Commerce & Industry t /PSUIFSO .JOEBOBP $IBNCFS of Commerce & Industry t 1BHBEJBO ;BNCPBOHB %FM 4VS Chamber of Commerce & Industry t ;BNCPBOHB $IBNCFS PG Commerce & Industry t ;BNCPBOHB 4JCVHBZ $IBNCFS of Commerce & Industry

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INTEGRITY IN PHILIPPINE BUSINESS:

FINDINGS FROM BENCHMARK STUDIES Tone from the top The Integrity Initiative conducted several benchmark studies to assess the extent to which ethical business practices have been institutionalized among organizations that have signed the Integrity Pledge. A series of surveys, online questionnaires, and focus group discussions were held in 2011 and 2012.

Tone from the top emerged as the single, most crucial component in enforcing ethical conduct in an organization. Participants in focus group discussions have consistently stressed the importance of top executives clearly communicating the company’s policy against bribery and corruption leading by example is also important. As one respondent states: “whatever policies we have in place, as long as we see our boss stuck in his ways, all efforts pushing for integrity in the workplace will be invalidated.” Ninety-seven percent of surveyed companies in 2011 stated that top management has already expressed clear instructions against bribery although the manner of expressing these instructions has yet to be investigated. Ethics of gift-giving Content analysis of signatories’ codes of business conduct indicates that there is no consensus on the range of acceptable practices in giving gifts and other tokens of hospitality. For some companies, items of modest value may be given to government officials as long as the gift given is legal, respectful of local customs and given in a transparent manner. A number of respondents in focus group discussions qualified “acceptable” gifts as those that are not big enough to give the impression of being a bribe while others have a zero-gift policy even during the holiday season. A number of companies explicitly prohibit political contributions.

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Audit rights on suppliers: A weak link? An organization’s ability to audit the ethical track record of their vendors and business partners is a key component in institutionalizing integrity in supply chain management. In a survey conducted in 2011 among Integrity Initiative’s early signatories, 30% of respondents declared that they do not have audit rights on suppliers. “Dealing with business partners” also registered as one of the lowest average scores in last year’s pilot Integrity Self-Assessment among selected signatories. The Integrity Initiative is working closely with industry associations specializing in procurement and supply chain management to support signatories in strengthening their control measures in this area. The SME Challenge The Integrity Initiative has conducted several consultations with small and medium business owners in Metro Manila, Davao, Cebu, and CALABARZON. Among the common concerns raised in these meetings include the vulnerability of SMEs when securing local permits and paying taxes. Business owners often feel “pressured” by frontline government agencies to pay bribes or grease money in order to complete basic transactions. There are, however, several indications of SMEs’ efforts to promote integrity within their own companies. Among the oft-cited examples include the owner’s open door policy to encourage employees to communicate their ethical dilemmas and creating procedures to ensure accuracy in financial reporting.

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INTEGRITY PLEDGE The Integrity Pledge is a commitment to ethical business practices and good corporate governance. Signed by an organization’s head, it establishes the tone from the top in practicing ethical business. There is neither a requirement nor screening process to sign the Pledge, only an onward commitment to implement the Pledge’s provisions. Signatories are part of a growing group of ethically-conscious companies spearheading positive change in the country.

We believe that corruption has been one of the biggest impediments to economic growth and prosperity in the Philippines and has been eroding the moral fiber of this society. As chief executives of established companies in the Philippines, we acknowledge our companies’ responsibility to lead by example in the fight against corruption and to operate our businesses ethically and with integrity. While the government has its own initiatives for reducing corruption, we realize that those initiatives cannot succeed without individual and collective commitment from businesses to level the playing field and to build integrity in the business environment. In view of the foregoing, we pledge the following: t 8F XJMM QSPIJCJU CSJCFSZ JO BOZ GPSN JO BMM BDUJWJUJFT under our control and ensure that our charitable and political contributions, business gifts, and sponsorships are transparent and will not be for the purpose of attempting to influence the recipient, whether government or private, into an improper exercise of functions, duties, or judgment. t 8F XJMM NBJOUBJO B $PEF PG $POEVDU UP HVJEF our employees towards ethical and accountable behavior at all times, and will apply appropriate sanctions for violations of the code. t 8F XJMM DPOEVDU USBJOJOH QSPHSBNT GPS PVS employees to promote integrity, honesty, and accountability in the exercise of their duties and responsibilities and to convey with resolve our company’s commitment to ethical business practices.

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t 8F XJMM JNQMFNFOU BQQSPQSJBUF JOUFSOBM TZTUFNT and controls to prevent unethical conduct by our employees, ensure good governance, and institutionalize the values of integrity and accountability in our business. t 8F XJMM NBJOUBJO BQQSPQSJBUF รถOBODJBM SFQPSUJOH mechanisms that are accurate and transparent. t 8F XJMM NBJOUBJO DIBOOFMT CZ XIJDI FNQMPZFFT and other stakeholders can raise ethical concerns and report suspicious circumstances in confidence without risk of reprisal, and a designated officer will be tasked with investigating all reports received. t 8F XJMM FOUFS JOUP JOUFHSJUZ QBDUT XJUI PUIFS businesses and with government agencies when dealing with procedures related to the bidding and procurement of supplies, materials, equipment, and construction. t 8F XJMM SFGSBJO GSPN FOHBHJOH JO CVTJOFTT XJUI parties who have demonstrated unethical business practices. To ensure collective action among business enterprises to foster ethical, clean, and transparent business transactions in the Philippines, we commit to: t TVQQPSU B OBUJPOXJEF JOJUJBUJWF JOUFOEFE UP create fair market conditions, transparency in business transactions, and ensure good corporate governance; t QBSUJDJQBUF JO SPVOEUBCMF EJTDVTTJPOT NFFUJOHT and forum to identify the key concerns and current problems affecting the private sectors related to integrity and transparency in business transactions;

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t TIBSF iCFTU QSBDUJDFw UPPMT BOE DPODFQUT XIJDI BSF intended to be used by all participating entities to achieve the goals of the nationwide initiative; t BTTJTU BOE DPOUSJCVUF JEFBT UP EFWFMPQ a unified “Business Code of Conduct” acceptable to all participating entities; t QBSUJDJQBUF JO UIF DSFBUJPO PG LFZ NFBTVSFT BOE control activities intended to ensure transparency, integrity and ethical business practice. t TVQQPSU UIF EFWFMPQNFOU PG BO BVEJU BOE certification program (including a training program for advisers and auditors) that will offer a toolbox for enterprises to introduce and implement ethical practices in their business processes; and institutionalize the whole process to promote sustainability of the Integrity Initiative.

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UNIFIED CODE OF CONDUCT FOR BUSINESS As a signatory of the Integrity Pledge, we are committed to upholding the highest standards of ethics in all our transactions. We firmly believe that securing profit at the expense of integrity is an unacceptable and unsustainable way of conducting business. Now is the time to drive the momentum towards the creation of fair market conditions in the Philippines. We express this collective commitment by adopting the Unified Code of Conduct for Business. We aim to institutionalize and promote honesty, transparency, and fairness in the business community by adhering to this Code. Top Management Our top management leads by example by consistently demonstrating the value of conducting business with integrity. Our officers strongly communicate our organization’s position against bribery*, corruption†, and unethical business practices within the company and the broader public; comply with all the requirements of government regulatory bodies; and prohibit cover-ups and falsified reports that conceal improper transactions. Management strongly supports integrity practices and allocates sufficient resources for their implementation. Human Resources We strive to instill a culture of integrity among our employees. The management maintains open lines

* The United Nations Convention Against Corruption defines bribery as “the promise, offering or giving, directly or indirectly, of an undue advantage to any person who directs or works, in any capacity, for a private sector entity, for the person himself or herself or for another person, in order that he or she, in breach of his or her duties, act or refrain from acting.”

Signatories of the Integrity Pledge are expected to abide by the Unified Code of Conduct for Business (the Code) What is the Code for? The Code’s purpose is two-fold: First, it harmonizes existing ethical standards among businesses operating in the Philippines. It ensures that different market players adhere to the same rules of the game in order to create fair market conditions and promote transparency in doing business. Second, the Code formally communicates the signatories’ commitment to upholding high standards of ethics in all business transactions. It articulates the belief that securing profit at the expense of integrity is an unacceptable and unsustainable way of conducting business and that measures have been taken to enforce and cultivate integrity habits within the signatories’ respective organizations.

† Corruption is the misuse of one’s position—or inducing others to do so—to improperly enrich himself or herself, or those close to him/her.

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How was it developed? The Code was developed over a period of five months, beginning from a survey of existing codes of conduct from signatories of the Pledge to engaging with roundtable discussions with academics from business schools, a series of focus group discussion with practitioners and consultations with auditing firms. Provisions in the Code are also aligned with national laws and international conventions on corruption and bribery.

of communication with employees, particularly on matters relating to honesty, transparency, and integrity in business transactions. In the spirit of fairness and due process, all employees have the right to file and respond to complaints against practices suspected to be illegal or unethical. We have appropriate tools to confidentially receive, monitor, and act on internal and external complaints. Employees filing complaints will be protected from all types of retaliation, while those involved in unethical practices will be subject to commensurate disciplinary actions. We have instituted training programs on business ethics covering all levels of the organization. Sales and Marketing We clearly communicate rules and guidelines on giving gifts, entertainment, tokens of hospitality, and contributions to/from public and private organizations and their representatives. Employees and all third parties engaged by our company to act as our intermediaries, agents, or representatives are not permitted to offer, promise, or give, as well as demand or accept concessionsâ&#x20AC;&#x201D;directly or indirectlyâ&#x20AC;&#x201D;in order to obtain, retain, or secure any undue advantage in the conduct of business. We abide by existing laws when transacting with government agencies (as stipulated under RA 6713 - Code of Conduct and Ethical Standards for Public Officials and Employees and RA 3019 - Anti-Graft and Corrupt Practices Act). Finance and Accounting We require all our employees to ensure that all books and records they create or are responsible for are complete and accurate. Our financial records conform to standard accounting principles, comply with Securities and Exchange Commission requirements on disclosure and transparency, and abide by antimoney laundering laws (RA 9160) and international conventions. We pay taxes in compliance with all laws.

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Procurement A track record of integrity and compliance with existing laws is a prerequisite when we vet third party consultants, suppliers, intermediaries, and agents. Our company has transparent procurement procedures, provides equal opportunities for all suppliers, and prohibits collusion between and among our employees and suppliers. Recognizing that the Integrity Initiative is sustained through widely shared ethical practices within the business community, we enter into integrity pactsâ&#x20AC;Ą with our suppliers and ensure that they comply with the provisions of our pact. Contracting a third party to bribe or commit corrupt practices on behalf of the company is strictly prohibited. Logistics We comply with laws and regulations pertaining to supply chain management. We do not tolerate any breaches in existing laws in exchange for undue advantage and unethical concessions or favors. We pay correct duties and taxes based on transparent assessments of goods and services. Employees are not penalized for refusing to pay bribes or facilitation payments even if it results in failure to meet deadlines or loss of revenue.

What are the expectations from signatories after adopting the Code? Participating organizations in the Integrity Initiative are expected to review their integrity practices and align their operations to the principles contained in the Code (whenever possible). Integrity habits should be institutionalized, particularly in focus areas that are susceptible to corruption including top management, human resources, procurement & logistics, sales & marketing, and finance & accounting. Signatories are also expected to consistently monitor their adherence to the Code and subject their control measures to external review, if necessary.

Implementation and Monitoring We will continually strive to align our operations to the principles contained in this Code and periodically assess and monitor our compliance to it. We will continue to share best practices with the business community to strengthen ethical business processes in the Philippines.

â&#x20AC;Ą Transparency International defines integrity pacts as written agreements between parties involved in procurement to refrain from bribery and collusion.

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THE INTEGRITY COMPLIANCE FRAMEWORK The Integrity Compliance Framework operationalizes the commitments participating companies made in the Integrity Pledge and the Unified Code of Conduct for Business. This framework serves as basis for subsequent steps in the Integrity Roadmap including the online self-assessment, external validation, and certification.

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The framework uses the diamond to symbolize integrity. Similar to the hardest natural substance on earth – the diamond – having integrity makes an organization strong, enabling it to withstand and endure challenges that will destroy its core. Among this the framework’s key features include the following: 1.

Integrity must be ingrained in the fabric of the organization. The diamond shows that the Integrity Compliance Framework is anchored on the organization’s mission, vision and core values, operationalized in the code of conduct and specific policies and guidelines, and embedded into the management systems and processes to ensure responsible decision-making in day-today business activities.

These are organized around tone from the top and practices from the ground up – areas that are both important in promoting integrity but also vulnerable to corrupt practices.

The framework identifies four key control measures, derived from global standards on corporate governance. These are (1) integrity governance and policy structure; (2) risk assessment; (3) documentation, communication, and reporting; and (4) implementation and monitoring.

The synergy among these components leads to the achievement of the Integrity Initiative’s goal of institutionalizing common ethical practices among companies.

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PROCESS FLOW FOR SIGNATORIES

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SELF-ASSESSMENT TOOL This online tool was designed for organizations, as a signatory of the Integrity Pledge, to help in gauging the extent to which participating organizationâ&#x20AC;&#x2122;s existing policies and practices are aligned with the Unified Code of Conduct for Business. (see p.13) Companies are also invited to take this opportunity to use the tool to reflect on existing strengths, best practices, and areas for improvement that can be used for planning and designing integrity improvement strategies As to who will accomplish the assessment, the participating organization can designate either a senior manager who is knowledgeable of the organizationâ&#x20AC;&#x2122;s operations, or a committee, with member-representatives cutting across the organization, where their individual assessments are aggregated to form a collective view. All responses are kept confidential by the Integrity Initiative.

The self-assessment tool aims to assist signatories of the Integrity Pledge in examining the scope and effectiveness of integrity policies and practices in their respective companies. This tool provides a framework that examines focus areas known to be susceptible to corruption and puts forward a set of control measures that can address these vulnerabilities. It gives companies an idea on how they fare in terms of integrity practices relative to other companies in their industry, location, or of their size. More importantly, the assessment tool provides areas for improvement to strengthen the companyâ&#x20AC;&#x2122;s overall integrity practices.

Before you proceed with the assessment, we suggest that you read the online FAQs section to learn more about the Integrity Initiative and the rationale behind this assessment.

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DEFINITION OF TERMS

Board of Directors

The governing body elected by the stockholders that exercises the corporate powers of a corporation, conducts all its business and controls its properties. (SEC definition)

Bribery

The promise, offering or giving, directly or indirectly, of an undue advantage to any person who directs or works, in any capacity, for a private sector entity, for the person himself or herself or for another person, in order that he or she, in breach of his or her duties, act or refrain from acting. (The United Nations Convention Against Corruption definition)

Business Partners

The Company’s suppliers of both goods and services. These may be vendors, contractors, consultants, financial partners (e.g. banks), intermediaries/ agents/ brokers, and others involved in supply chain management.

Compliance Officer

The employee responsible for managing the company’s systems of internal control and providing support to all employees in order to comply with laws, regulations and internal procedures and ethical standards.

Control measures

Actions or activities used to prevent or detect violations of laws, regulations, and ethical standards. (see internal control)

Corruption

The misuse of one’s position—or inducing others to do so—to improperly enrich himself or herself, or those close to him/her.

Corporate Governance

The framework of rules, systems and processes in the corporation that governs the performance by the Board of Directors and Management of their respective duties and responsibilities to the stockholders. (SEC definition)

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Finance and Accounting Focus area in-charge of the companyâ&#x20AC;&#x2122;s financial records, day-today services related to the inflow and outflow of resources and oversight of the companyâ&#x20AC;&#x2122;s financial health. Human Resources

Focus area in-charge of management of employees in a company including hiring, promotion, training and development, and performance evaluation.

Integrity Pacts

Written agreements between parties involved in procurement to refrain from bribery and collusion. (Transparency International definition)

Integrity Risk

Ethical and compliance risks affecting the integrity of the organization

Internal control

The system established by the Board of Directors and Management for the accomplishment of the corporationâ&#x20AC;&#x2122;s objectives, the efficient operation of its business, the reliability of its financial reporting, and faithful compliance with applicable laws, regulations and internal rules. (SEC definition)

Internal control system

The framework under which internal controls are developed and implemented (alone or in concert with other policies or procedures) to manage and control a particular risk or business activity, or business activities, to which the corporation is exposed. (SEC definition) (see compliance officer; control measures)

Logistics

Focus area in-charge of the management of flow of goods from origin to destination.

Management

The body given the authority by the Board of Directors to implement the policies it has laid down in the conduct of business of the corporation. (SEC definition)

Organizational Integrity Adherence of the organization to a strict moral or ethical code resulting from well-defined core values and principles and translated into management processes and procedures

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Procurement

Focus area in-charge of obtaining products and services a company needs for operations.

Risk

The effect of uncertainty on objectives (ISO 31000 definition)

Risk Assessment

The identification, assessment, and prioritization of risks, followed by the coordinated set of activities to minimize, monitor, and control the probability and/or impact of unfortunate events (adapted from ISO 31000 definition)

Sales and Marketing

Focus area in-charge of selling goods and services to the companyâ&#x20AC;&#x2122;s clients.

Signatories

Organizations that have expressed commitment in implementing ethical business practices by signing the Integrity Pledge.

Top Management

The highest ranking executives in the organization including the chairperson, CEO, managing director, executive directors and other senior managers. For smaller companies, this includes business owners and those in the position to make decisions on behalf of the entire company. (see board of directors; management)

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Part I: About the organization Name of organization: Business address:

Number of years in operation (please tick the appropriate box) ¸ 0 -5

¸ 6-10

¸ >10

Number of employees (please tick the appropriate box) ¸ 1-9

¸ 10-99

¸ >200

Nature of business (please tick the appropriate box) ¸ Agriculture

¸ Industry

¸ Services

¸ Others (please specify)_____________

Part II: About the respondent Name of respondent: Position/designation: Division/department: Length of service in organization: Phone/s: Fax: Email: Date of submission:

How to Use the Integrity Self-Assessment Tool 1.

The assessment is organized around six focus areas. The first focus area of the tool enumerates a series of statements regarding top management’s policies and practices that promote and institutionalize integrity in your organization. The second to the sixth focus areas are statements related to the ways in which your organization ensures that integrity is practiced when dealing with: employees, clients, business partners,

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finances, and government, communities, environment, and other key stakeholders. 2.

To respond to the statement, select the level of implementation of integrity practices in your organization.

Put a check (X) in the appropriate rating column (see example below) according to the definitions provided.

Not Done

Beginning

Expanding Consistent

Advanced

RATING LEVEL KEY Rating Level

Definition

Not Done

The organization has not taken specific steps on implementing integrity standards

Beginning

The organization is starting to implement measures or already implementing but not yet documented

Expanding

The organization is systematizing its approach and moving towards organization-wide implementation of integrity standards

Consistent

The organization implements integrity standards organization-wide and evaluates its effectiveness for continuous improvement

Advanced

The organization has demonstrated best practices on this matter

â&#x20AC;&#x153;Not Applicableâ&#x20AC;? (NA) is not considered as an option in the Rating Level entries. While some statements may seem to be more applicable for large-scale or multi-national companies, the interpretation of the statement must consider equivalent ways of doing things in the Small and Medium Enterprises (SMEs). The intent behind the statement, which is that of compliance at the minimum, remains.

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Focus Area 1: Top Management

7. 8. 9. 10. 11. 12. 13.

14. 15.

Advanced

4. 5. 6.

Consistent

Expanding

Beginning

Not Done

Top management refers to the highest ranking executives in the organization including the chairperson, CEO, managing director, executive directors and other senior managers. For smaller companies, this includes business owners and those in the position to make decisions on behalf of the entire company.

Top management actively promotes and enforces a culture of integrity in the company Top management has communicated clear instructions against bribery and other corrupt practices and the consequences on non-conformance The company has a code of conduct that is consistent with the provisions in the Integrity Initiativeâ&#x20AC;&#x2122;s Unified Code of Business Conduct Top management has cascaded its companyâ&#x20AC;&#x2122;s code of conduct to all employees The company regularly reviews the content of the companyâ&#x20AC;&#x2122;s code of conduct Top management has a clearly laid out integrity governance and policy structure (or counterpart) Integrity and ethical track record is part of the process for selecting members of top management Top management participates in the conduct of regular integrity risk assessment process Top management allocates enough resources to support the implementation and maintenance of integrity practices The company has a mechanism to ensure that emerging integrity risks related to unethical conduct are identified and addressed through an action plan explaining ways to mitigate and address these risks Results of integrity risk assessment exercises are disseminated to relevant employees The corporate secretary and/or other responsible employees ensure the preservation of the integrity of corporate records Top management has a process for reviewing compliance with the following (consider only those applicable to your organization): t $PNQBOZ T DPSQPSBUF HPWFSOBODF NBOVBM t $PSQPSBUF HPWFSOBODF MBXT t -BCPVS MBXT t -PDBM PSEJOBODFT t "QQMJDBCMF FOWJSPONFOU IFBMUI TBGFUZ &)4 MBXT Members of board of directors and other senior managers disclose conflicts of interest Top management takes part in regular trainings, seminars or conventions on ethical standards and corporate governance, either as participant or resource person

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Focus Area 2: Dealing with fellow employees

Each employee has been informed of the risks associated to his/her position, including sanctions and penalties, in relation to committing unethical practices

Each employee has been given instructions on how to handle risks associated to unethical practices

Employees take part in education and training programs on ethical decisionmaking that are appropriate for their rank and responsibilities

Managers and supervisors are constantly updated on the global best practices on business ethics

The company has programs that engage employees and strengthen their values (e.g. “Integrity Circles”)

The company has formal channels where suspicions of corrupt practices committed by employees and top management can be reported (whistle blowing facilities)

Track record of integrity is considered when hiring new employees

10.

Track record of integrity is considered in employee evaluation and promotion

11.

Track record of integrity is significant in employee separation in the sense that employees voluntarily separating from the company are commended for their ethical conduct during their tenure while employees discharged due to unethical conduct are made aware of the circumstances of their termination

12.

There is/are employee/s specifically designated to monitor fellow employees’ compliance with integrity policies

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Advanced

The company has clear levels of authority when dealing with cases of unethical conduct

Consistent

Expanding

The company has mechanisms that monitor employees’ compliance with the code of conduct

Beginning

Not Done

Market research adheres to ethical standards particularly in data collection

Advanced

1a.

Consistent

Business ethics is integrated in the development of sales and marketing plans, as indicated in the following statements:

Expanding

Beginning

Not Done

Focus Area 3: Dealing with clients

C -BXT BOE SFHVMBUPSZ SFTUSJDUJPOT BSF DPOTJEFSFE JO UIF QMBOOJOH QSPDFTT 1c.

Employees involved in the bidding process are given clear instructions to strictly follow the rules of bidding

1d.

The company discloses all relevant information when dealing with clients

Sales and marketing employees (or counterparts) have been given clear instructions to act honestly and fairly at all times

Employees and sales agents have been informed of their responsibility to comply with the following (consider only those applicable to your organization): t $POTVNFS "DU PG UIF 1IJMJQQJOFT 3"

t $PEF PG $POEVDU BOE &UIJDBM 4UBOEBSET GPS 1VCMJD 0ĂłDJBMT BOE Employees (RA 6713) t 3FRVJSFNFOUT PG SFHVMBUPSZ BHFODJFT UP QSPUFDU UIF JOUFSFTUT PG customers, the market and society t 3FHVMBUJPOT PO BEWFSUJTJOH t 0CMJHBUJPOT XJUI JOEVTUSZ BTTPDJBUJPOT t (PWFSONFOU 1SPDVSFNFOU 3FGPSN "DU 3"

t "QQMJDBCMF JOUFSOBUJPOBM MBXT USBEF BHSFFNFOUT FUD

Employees as well as agents have been given clear guidelines on resolving FUIJDBM EJMFNNBT PS DPOĂ¸JDUT PG JOUFSFTU (VJEFMJOFT NBZ CF PO HJWJOH HJGUT and tokens of hospitality to clients, representation and entertainment, sponsorships and donations, political campaign contributions, etc.

Sales and marketing representatives participate in the regular integrity risk assessment process

Employees are given explicit instructions when dealing with clients asking for bribes or gifts

The company has mechanisms for employees to report clients demanding bribes and facilitation fees

Track record of integrity is considered when accrediting sales agents

The company has a system for recording, safekeeping and backing up contracts, invoices, receipts and the like

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Focus Area 4: Dealing with business partners

There are procedures to audit suppliersโ compliance with integrity pact

5IFSF BSF QSPDFEVSFT UP BVEJU QSPDVSFNFOU PรณDFST PS DPVOUFSQBSU

1SPDVSFNFOU -PHJTUJDT SFQSFTFOUBUJWFT QBSUJDJQBUF JO UIF SFHVMBS JOUFHSJUZ SJTL assessment process including the identification of fraud risk areas

The company conducts thorough examination and due diligence prior to hiring third party consultants, suppliers, contractors, intermediaries and agents particularly in relation to their risk of involvement in bribery and corrupt practices

There is a procedure for suppliers, procurement agents and business partners to report employees demanding bribes/facilitation payments and committing unethical business practice

There are processes to regularly evaluate the effectiveness of integrity policies when dealing with suppliers and third parties

1SPDVSFNFOU PรณDFST BHFOUT SFDFJWF USBJOJOH PO CVTJOFTT FUIJDT BQQSPQSJBUF GPS their rank and responsibilities

1SPDVSFNFOU PรณDFST IBWF BDDFTT UP UIJSE QBSUZ DFSUJรถDBUJPO (ex: Certified Professional in Supply Chain Management)

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Advanced

The company enters into integrity pacts with selected suppliers

Consistent

Expanding

Business ethics is integrated in procurement procedures and supply chain management, as indicated in the following statements: 1a. The company has a clear written policy and procedures on bidding, negotiations, supplier selection and performance evaluation 1b. Track record of integrity is a criterion for selecting suppliers and other business partners 1c. The company has clear written rules on receiving gifts from suppliers and other third parties E 5IFSF JT B DMFBS XSJUUFO QPMJDZ PO EJTDMPTVSFT PG SFMBUJWFT BOE BรณMJBUFT PG QSPDVSFNFOU PรณDFST BOE PUIFS FNQMPZFFT JOWPMWFE JO UIF TVQQMZ DIBJO management from bidding to delivery 1e. There is a clear written policy on its own employees participating in bids for materials or services the company is procuring 1f. The company has a clear written policy on sanctions to penalize suppliers that have committed unethical practices

Beginning

Not Done

Business partners refer to the companyโ s suppliers of both goods and services. These may be vendors, contractors, consultants, financial service providers (e.g. banks, insurance companies), intermediaries/agents/brokers, and others involved in supply chain management.

The company has a mechanism to ensure the accuracy of financial records

1b.

The company conforms to standard accounting and auditing principles, local and international, as appropriate

1c.

The company clearly segregates duties and responsibilities of finance and accounting positions

1d.

The company has a process for evaluating the effectiveness of its financial management system

1e.

The company has a specific policy for handling bank accounts and cash payments

The company has an independent auditor as prescribed by law

The company has a process for selecting a qualified auditor

Finance and accounting employees participate in regular risk assessment process

The company has mechanisms to prevent, detect and respond to accountingrelated fraud

Board members have access to corporate financial reports

Financial reports are disseminated to relevant persons in a timely manner

There is a secure mechanism to store, back up, readily access and retain financial records

Advanced

1a.

Consistent

Business ethics is integrated in budget development and financial planning, as indicated in the following statements:

Expanding

Beginning

Not Done

Focus Area 5: Dealing with finances

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Employees have been trained on ethical decision-making when dealing with cases of extortion and other forms of unethical conduct

5IFSF BSF NFDIBOJTNT GPS FNQMPZFFT EFBMJOH XJUI HPWFSONFOU PĂłDJBMT UP report incidents of corruption

The company has a process to ensure employees comply with the following (consider only those applicable to your organization): t "OUJ .POFZ -BVOEFSJOH "DU 3"

t /BUJPOBM *OUFSOBM 3FWFOVF $PEF 3" t (PWFSONFOU 1SPDVSFNFOU 3FGPSN "DU 3"

t 1IJMJQQJOF 'JOBODJBM 3FQPSUJOH 4UBOEBSET

The company pays the right taxes

The company pays mandated employee benefits F H 444 1IJM)FBMUI 1BH JCJH

The company has clear programs and policies that guide its conduct and outline its social responsibilities towards the community and the environment

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Advanced

Employees have been informed of their positionâ&#x20AC;&#x2122;s vulnerability to unethical practices when dealing with government

Consistent

Expanding

All employees have been informed of their legal obligations and rights associated to their rank and responsibilities

Beginning

Not Done

Focus Area 6: Dealing with government, communities, environment, and other key stakeholders

Scoring sheet per company 1. 2. 3. 4. 5.

Column (A) represents the score per Focus Area Column (B) shows the maximum points per Focus Area The grand totals of (A) and (B) are at the bottom row Column (C) represents the weighted (in terms of no. of statements) score per Focus Area Column (D) indicates the meaning of the weighted score in terms of the level of implementation of integrity practices

Focus Area

Assessment Rating Totals

Maximum Points

1. Top management

2. Dealing with employees

3. Dealing with clients

4. Dealing with business partner

5. Dealing with finances

6. Dealing with government, communities, environment and other stakeholders

Total

Weighed Focus Area Score

Level of Implementation of Integrity Practices

296

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Levels of implementation of organizational integrity practices The Overall Score is the summation of the scores for each of the six focus areas. It describes the level of implementation of integrity practices of an organization. The maximum Overall Score is 296. The figure below shows the scoring ranges describing each level of implementation of an organizationâ&#x20AC;&#x2122;s integrity practices.

Integrity practices are mainstreamed in the organization; Demonstrated best practices. Integrity practices are continuously evaluated and improved Implementing systematic integrity practices organization-wide Starting to implement integrity practices or implementing but lacks systematic process Integrity practices are non-existent

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EXTERNAL VALIDATION After completing the self-assessment tool, the organization analyzes the results and considers corrective measures to address identified vulnerabilities. The next step is to open up the assessment to an external validator who can independently and rigorously re-examine the organizationâ&#x20AC;&#x2122;s progress in institutionalizing integrity practices. This primarily involves documentary checks conducted by a qualified validator trained and accredited by the Integrity Initiative. The outcome of this activity is a score sheet that compares findings from the self-assessment with the external validation. The aim is to compare the organizationâ&#x20AC;&#x2122;s selfidentified strengths and weaknesses with the validatorâ&#x20AC;&#x2122;s findings. This can help address possible oversight in self-assessment and can be remedied by improving particular control measures. Documentary evidence checked during external validation include the following: Focus Area 1: Top management 4. 6. 8. 9. 10. 11. 12. 13. 14. 15.

4USBUFHJD 4UBUFNFOUT 7JTJPO .JTTJPO $PSF 7BMVFT $PSF $PNQFUFODJFT (PBMT

*OUFHSJUZ (PWFSOBODF BOE 1PMJDZ 4USVDUVSF BSUJDVMBUFE JO BO *OUFHSJUZ %FWFMPQNFOU 1MBO (or counterpart), written memo or document, etc. 0SHBOJ[BUJPO DIBSU JOEJDBUJOH DPNNVOJDBUJPO SPVUFT Roles and lines of accountability 503 TJHOFE CZ NFNCFST PG UPQ NBOBHFNFOU Section in company manuals (Code of conduct, corporate governance manual, etc.) -JTU PG TJHOBUPSJFT F H FNQMPZFFT TUBLFIPMEFST DMJFOUT TVQQMJFST CSPBEFS QVCMJD XIP have been informed of the integrity governance and policy structure Corporate governance manual Corporate governance laws Integrity risk assessment process Integrity risk assessment reports Instructions against bribery and other corrupt practices Means of communication of instruction such as company manual, memo to employees, company newsletter, website, etc. Process for selecting members of top management Protocol for recordkeeping, retrieval, access, back-up and preservation, etc.

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16. 17. 18. 19.

Scorecard (internal/company, ICD, SEC, PSE, etc.) Process for monitoring compliance with corporate governance manual, corporate governance laws, labor laws, labor ordinances, etc. Written disclosures of conflict of interest by the members of the board Certificates of participation/completion or commendation/appreciation for attending training, conferences, as a participant or resource person

Focus Area 2: Dealing with fellow employees 1. 2. 3. 4. 5. 6. 7. 8. 9. 10.

Companyâ&#x20AC;&#x2122;s Integrity Development Plan or counterpart Code of Conduct for employees Employee handbook Incident reports Integrity risk assessment process Integrity risk assessment reports Process for reporting corrupt practices committed by employees and top management Employee recruitment process Employee development process Employee evaluation and promotion process

Focus Area 3: Dealing with clients 1. 2. 3. 4. 5. 6. 7. 8.

Companyâ&#x20AC;&#x2122;s Integrity Development Plan or counterpart Code of Conduct for employees Employee handbook Marketing manual Process for employees to report clients demanding bribes and facilitation fees Process for clients to report employees offering bribes and facilitation fees Integrity risk assessment process Integrity risk assessment reports

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Focus Area 4: Dealing with business partners 1. 2. 3. 4. 5. 6. 7. 8. 9.

Companyâ&#x20AC;&#x2122;s Integrity Development Plan or counterpart Code of Conduct for employees Employee handbook Procurement manual Supply chain management manual Procedure for negotiating with suppliers Suppliersâ&#x20AC;&#x2122; manual containing guidelines for conducting business with the company Rules on conflict of interest Rules on receiving gifts from suppliers and third parties %JTDMPTVSFT PG SFMBUJWFT BOE BĂłMJBUFT PG QSPDVSFNFOU PĂłDFST BOE PUIFS FNQMPZFFT JOWPMWFE in the bidding 11. Policy on its own employees participating in bids for materials or services the company is procuring 12. Policy on sanctions to penalize suppliers and employees that have committed unethical practices 13. Integrity pacts with suppliers 14. Process of announcing â&#x20AC;&#x153;Invitation to Bidâ&#x20AC;? 15. System for recording, safekeeping and backing up contracts, invoices, and receipts 16. Process for suppliers/procurement agents to report employees demanding bribes/ facilitation payments and committing unethical business practice 1SPDFTT GPS QBSUOFST J F DVTUPNT PĂłDJBMT QSJWBUF TFDUPS QBSUOFST UP SFQPSU FNQMPZFFT third parties 18. Process for employees to report suspected anomalies in logistics processes 19. Integrity risk assessment process 20. Integrity risk assessment reports

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Focus Area 5: Dealing with finances 1. 2. 3. 4. 5. 6. 7. 8. 9. 10.

Companyâ&#x20AC;&#x2122;s Integrity Development Plan or counterpart Code of Conduct for employees Employee handbook Finance and accounting manual Audit committee charter Process for employees to report suspected anomalies in financial reporting Integrity risk assessment process Integrity risk assessment reports Financial reports Process for storing, accessing, preserving and backing up financial records

Focus Area 6: Dealing with government, communities, environment, and other stakeholders 1. 2. 3. 4. 5. 6. 7. 8. 9. 10.

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CERTIFICATION By the end of 2014, the Integrity Initiative aims to set up an Integrity Certification Program similar to the *40 5IF *OJUJBUJWF XJMM EFWFMPQ B QPPM PG USBJOFE BDDSFEJUPST UIBU XJMM DPOEVDU WJTJUT BOE TQPU DIFDLT UP BTTFTT the level of institutionalization of integrity practices. Companies that have a good track record of enforcing business ethics can invite the Integrity Initiative to examine their processes for certification. Certified companies can avail of incentives with the government and other private sector partners. Details of incentives are currently being worked out. Aside from examining documentary evidence, accreditors will also conduct:

A survey on ethical practices that aims of measure the level of employeesâ&#x20AC;&#x2122; awareness and understanding of the organizationâ&#x20AC;&#x2122;s integrity policy (based on systematic random sampling considering the rank and department of respondents)

Focus group discussions (design depends on the size and nature of the organization)

Key informant interviews (based on purposive sampling)

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COMMUNICATING INTEGRITY:

TIPS AND BEST PRACTICES The Integrity Initiative convened a series of roundtable discussions with communication experts to share best practices in promoting integrity habits in different organizations. Here are the highlights:

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COMMUNICATIONS NEEDS ASSESSMENT WORKSHEET This is a simple worksheet published in the US Department of Commerceâ&#x20AC;&#x2122;s Business Ethics Manual for emerging markets. It can be used to assist business owners and managers in conducting communications needs analysis using standard assessment tools.

Interviews

Focus Groups

Surveys

Document Review

Direct Observation

What kinds of responsible business conduct issues do employees and other stakeholders face or are they concerned about? What do employees and other stakeholders need to know to be able to fulfill their roles and responsibilities and have reasonable expectations of the enterprise? How do employees and other stakeholders learn what is expected of them and what they can expect? What communications methods are available to the enterprise to reach specific stakeholders? What are the criteria by which successful communications will be evaluated?

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PROGRESS REPORT OF INTEGRITY INITIATIVE’S PARTICIPATING ORGANIZATIONS As of 30 June 2013, participating organizations have demonstrated different levels of progress in completing the Initiative’s road map. Most organizations have yet to undertake the Integrity Initiative’s self-assessment and benchmark the extent to which their current policies and practices adhere to the Unified Code of Conduct for Business.

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RESOURCES The Integrity Initiative has put together several online resources that can help signatories plan, implement and monitor their respective integrity compliance programs. Global conventions and initiatives on corporate governance American Institute of CPAs (2011) International Financial Reporting Standards: An AICPA Backgrounder http://www.ifrs.com/pdf/IFRSUpdate_V8.pdf Asia-Pacific Economic Cooperation (2007) APEC Anti-Corruption Code of Conduct for Business http://www.apec.org/Groups/SOM-Steering-Committee-on-Economic-and Technical-Cooperation/Task-Groups/~/media/Files/Groups/ACT/07_act_ codebrochure.ashx Asian Development Bank (2004) Definitions of Corruption http://www.adb.org/documents/policies/anticorruption/anticorrupt300. asp?p=policies Organization for Economic Cooperation and Development (2011) Convention on Combating Bribery of Foreign Public Officials in International Business Transactions http://www.oecd.org/dataoecd/4/18/38028044.pdf Partnering against Corruption Initiative https://members.weforum.org/pdf/paci/principles_short.pdf United Nations Office on Drugs and Crime (2004) United Nations Convention against Corruption http://www.unodc.org/documents/treaties/UNCAC/Publications/Convention/0850026_E.pdf (see Article 12 on the role of the private sector)

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National laws and conventions on business ethics and corporate governance Bureau of Internal Revenue (2004) Guide to Philippine Tax Law http://www.bir.gov.ph/legalmatters/8757.htm Republic Act No. 3019 (1960) Anti-graft and Corrupt Practices Act http://unpan1.un.org/intradoc/groups/public/documents/APCITY/UNPAN019094. pdf Republic Act No. 6713 (1989) Code of Conduct and Ethical Standards for Public Officials and Employees. An act establishing a code of conduct and ethical standards for public officials and employees, to uphold the time-honored principle of public office being a public trust, granting incentives and rewards for exemplary service, enumerating prohibited acts and transactions and providing penalties for violations thereof and for other purposes. http://excell.csc.gov.ph/cscweb/RA6713.html Republic Act No. 9160 (2001) Anti-Money Laundering Act of 2001 http://www.amlc.gov.ph/archive/RA9160.html Securities and Exchange Commission (2002) Code of Corporate Governance for Registered Issuers and Public Companies http://www.sec.gov.ph/notices/draft/code_corporate_governance-ii.htm

(#4+5(*#4

ACKNOWLEDGMENTS This handbook was completed through the collective effort of the Integrity Initiative team, Integrity Consortium and their representatives, the Technical Working Group and participants in our focus group discussions. Integrity Initiative Team Peter Perfecto, Project Director, MBC Henry Schumacher, Project Director, ECCP Jose Cortez, Project Coordinator, MBC Gerry Constantino, Project Coordinator, ECCP Maeflor Gabunales, Project Officer, MBC Nonette Climaco, Project Officer, ECCP Roy Villafania, Project Assistant, MBC Zyra Fastidio, Project Assistant, ECCP Paulo Prieto, Mindanao Regional Assistant, MBC Monette Mabanag-Flores, Visayas Regional Assistant, ECCP Integrity Consortium Advertising Board of the Philippines, Ricky Alegre American Chamber of Commerce of the Phils., Rhicke Jennings Asian Institute of Management, Edilberto de Jesus Association of Certified Fraud Examiners, Bonifacio Sam Association of Development Financing Institutions in Asia & The Pacific, Octavio Peralta Australian-New Zealand Chamber of Commerce, John Casey Bankers Institute of the Philippines, Salvador Serrano Bishops-Businessmenâ&#x20AC;&#x2122;s Conference for Human Development, Meneleo Carlos British Chamber of Commerce, Michael Whiting Canadian Chamber of Commerce, Julian Payne Coalition Against Corruption, David Balangue Employersâ&#x20AC;&#x2122; Confederation of the Philippines, Edgardo Lacson European Chamber of Commerce of the Phils., Michael Raeuber Federation of Filipino Chinese Chamber of Commerce & Industry, Inc., Dr. Alfonso Uy Financial Executives Insititute of the Philippines, Ramon Opulencia Foundation of Society of Fellows of Supply Management, Ricardo Joaquin Sison

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French Chamber of Commerce, Ernst Wanten German Philippine Chamber of Commerce of the Philippines, Reiner Allgeier Good Governance Advocates & Practitioners of the Philippines, Vincent Edward Festin Institute of Corporate Directors, Ricardo Nicanor Jacinto Management Association of the Philippines, Melito Salazar Makati Business Club, Ramon Del Rosario Jr. People Management Association of the Philippines, Grace Sorongon Philippine Chamber of Commerce & Industry, Amb. Francis Chua Philippine Constructors Association, Levy Espiritu Philippine Institute of Supply Management, Mariel Zamora Philippine Marketing Association, Vince Reyes Philippine Society of Training & Development, Caroline Tiamson Procurement and Sourcing Institute of Asia, Charlie Villasenor Public Relations Society of the Philippines, Ramon Isberto Technical Working Group Aliza Racelis, College of Business Administration, University of the Philippines April Therese Bernandino, Isla Lipana & Company Colin Hubo, Center for Social Responsibility, University of Asia & Pacific Gloria Talavera, College of Business Administration, University of the Philippines Grace Aries, Isla Lipana & Company Joy Rabo, Center for Professional Development in Business & Economics, De La Salle University Juan Carlos Robles, Punongbayan & Araullo Leonardo Matignas Jr., SGV & Company Luisito Amper Jr., Navarro Amper & Company Ma. Theresa Toyn, Lane Archive Technologies Marjorie Merced, Siemens Phils., Inc. Oliver Bucao, Manabat Sanagustin & Company Raymond Habaradas, Management & Organization Department, De La Salle University Focus group discussion participants Abigail Ho, SeaOil Phils. Albert Collado II, Microlab Aldrin Dulig, Convergys Corp. Alejandro Buan, Buan & Associate Law Office Alice Salita, ING Bank Manila /*2&+8.#0',#&!4

Focus group discussion participants Alvin Yu, Liquigaz Phils. Andrew Valenzuela, Royal Cargo Combined Logistics Anna Marie Agcaoili &ODIBOUFE ,JOHEPNF *OD Anna Marie Lourdes Pascual-Cenzon, Pascual Laboratories Arturo Ilano, University of the Philippines Bernadette Cabie, American Technologies Inc. Bing Tomada, D Big Man Shining Business Bonnel Jomento, C.M. Pancho Construction Inc. Brian Gozun, De La Salle University Carla Paras-Sison, Lopez Holdings Corp. Carlos Carado, Isla Lipana & Co. Carmen McTavish, Angeles International Travel Center Cedi Cutanda, Bayer Phils. Celia Imperial, Blue Cross Insurance Inc. Charisse Yacapin, Jollibee Foods Corp. Charlie Villasenor, PASIA Dan Pamintuan, ABServe Airconditioning Diosdado Espinoza, Microlab Donnies Alas, Alas, Oplas & Co. Dorothy Legaspi, Austriamicrosystems Edgard Tordecilla, Siemens Inc. Phils. Edwardo Santos, GMA Network Inc. Elaine Mapa, Pag-ibig Fund Emmanuel Danion, Bureau Veritas F. Francisco Zaldarriaga, Carmelray Group of Companies Felipe Yalong, GMA Network Inc. Fortune Tayag (4, 1IJMT *OD Francis Glenn Yu, Seaoil Phils. Francis Manas, M&H Food Corp. Fritz Pangan, Seaoil Phils. Fritzie Mendenilla, JEC Phils. Gary Huang, Emilio Aguinaldo College Guenter Taus, Jardine Energy Haidee Enriquez, People Management Association of the Philippines Hanica Pacis, Convergys Corp. Jane Manalansang, Chevrolet Phils. â&#x20AC;&#x201C; The Covenant Car Co. Janine Carreon, Manila Water Co. Jason Meruena, DB International Sales & Services Jed Poblete, Citimex Inc.

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Focus group discussion participants Jennielyn Abana, SeaOil Phils. Jera Padua, TĂ&#x153;V Rheinland Jing Arkoncel, Total Phils. Joewar Cadungog, Punongbayan & Araullo Joey Jao, Seaoil Phils. Johnny Filart, Ateneo de Manila University Jones Campos, ADBOARD Joseph Carballo, The Medical City Juan Carlos Robles, Punongbayan & Araullo Junie Del Mundo, EON Inc. Laarni Holdiem, Liquigaz Phils. Corp. Laura Victoria A.S. Yuson-Layug, Baniqued & Baniqued Leilani Galvez, LLG Accounting Firm Leonardo Matignas Jr., SGV & Co. Levy Espiritu, Datem Inc. Lorna Pabelico, Malayan Insurance Co. Inc. Luis Martin Tan, Baniqued & Baniqued Lulu Cervantes, MSD Phils. Ma. Carmela Peralta, Manabat Sanagustin & Co. Ma. Cristina Viola, SeaOil Phils. Ma. Victoria Espano, Punongbayan & Araullo Mailyn Ocampo (4, 1IJMT Mar Cortez, Danilynâ&#x20AC;&#x2122;s Enterprise Inc. Margarita Reyes, Business Machines Corp. Maribel Porras, Eurocopter Phils. Maricel Cambe, Liquigaz Corp. Marilou Sibayan, Jollibee Foods Corp. Mario Lazatin, Trilan Realty Inc. Mark Parulan, Chevrolet Phils. â&#x20AC;&#x201C; The Covenant Car Co. Mary Grace Gallen, ICCP Group Michelle Tayag, Metro Angeles Chamber of Commerce and Industry Inc. Myra Rivera, Angeles Electric Corp. Nestor Constancia, Gardenia Bakeries Phils. Inc. Paul Guevarra, SeaOil Phils. Rachelle Ismael, Royal Cargo Combined Logistics Raem Mendoza, Colegio de San Juan de Letran Ramon Mayuga, Ateneo de Manila University Rey Rabago, Adamson University Ricky Alegre, ADBOARD/UPMG /*2&+8.#0',#&!4

Focus group discussion participants Ricky Rivera, Pascual Laboratories Roderick Vega, SGV & Co. Roland Ngo, Convergys Corp. Rommel Penafiel, D & W Ads Romulo Sison, Banaria, Banaria & Co. Ron Jabal, Shell Phils. Ronaldo De Dios, Makati Medical Center Rose Mariano, MSD Phils. Selene Lee Yu, Chevrolet Phil. â&#x20AC;&#x201C; The Covenant Car Co. Shella Duran, Goudie Associates Manila Ltd. Co. Stephen Uy, Blue Cross Insurance Inc. Sylvia Gotuaco, ING Bank Manila Teresa Pacis, GMA Network Inc. Toby Nebrida, Shell Phils. Tony Roldan, Transparency International Phils./HRD Phils. Trixie Arriolla, Jones Lang Lasalle Val Baac, Emilio Aguinaldo College Veronica Elizalde, University of the East Vincent Raymond Cruz, Microlab Wilfredo Villanueva, SGV & Co.

Project Consultants Elena Cruz Nicole Curato Resureccion Alip

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