Reflection on Integrity Management While Engaging with Third Parties in the Construction and Civil Engineering Industry

Abstract

This reflection aims to investigate the integrity-related risks for companies engaging with third parties in the construction and civil engineering industry. The business partner compliance process of a multinational construction engineering company is assessed through internal interviews with integrity officers per business sector and per region in a static and dynamic strategy framework. The actual process is the internal evaluation of a ready-made tool bought from a service supplier that assess how the risks related to corruption are covered in order to determine the level of due diligence necessary when This material may be downloaded for personal use only. Any other use requires prior permission of the American Society of Civil Engineers. This material may be found at https://doi.org/10.1061/(ASCE)LA.1943-4170.0000435. engaging with a specific third party. This study finds that companies must involve their own experts to improve integrity tools. Collecting expert opinions on risk is necessary to allow an improved understanding of the scope of the tool. This study reflects on new ways for improving the integrity tool and demonstrates the necessity to cover risks not solely associated with Corruption & Bribery, but also with Human Rights, Conflict of Interest, Antitrust & Competition, as well as Compliance with Regulations to fully protect company's integrity.

Methodology for Conducting Third-Party Risk-Based Due Diligence in the Construction and Civil Engineering Industry

“…Key risk indicators for integrity risk assessment are the geographic location, the type of industry, the partner profile, the proximity to public officials, the reasons for the partnership, the type of remuneration and the type/complexity of the contract (PACI 2013, Dow Jones Risk & Compliance 2018, NAVEX Gobal 2018, Roy, Desjardins et al 2021. The evaluation of these indicators determines the appropriate risk level, and therefore, the level of scrutiny necessary.…”

“…For the purpose of this study, content for the tool will be proposed. The steps, content and format were determined following a review of the literature and of references, as well as from an internal survey previously conducted at the company's Integrity department (Roy, Desjardins et al 2021). The company previously experienced corruption-related misconduct, which ultimately led to a complete change in its ethics culture.…”

“…This code reflects the company's objectives. For integrity assessment, the main performance indicator would be whether or not employees are complying with the code since having integrity represents walking the talk with the image the company projects (Roy, Desjardins et al 2021).…”

“…An internal survey was recently conducted at the company among 14 ethics and risk management experts. The respondents were asked to identify the strengths and weaknesses of the current business partner compliance process and to identify threats and positive developments in their fields of expertise regarding integrity management (Roy, Desjardins et al 2021). They were also asked to score six different risk indicators according to the five integrity-related risks.…”

“…The content from an internal survey conducted in a multinational construction and engineering firm about third-party risks will be used (Roy, Desjardins et al 2021). The survey was conducted among integrity, ethics and compliance experts at SNC-Lavalin (referred to as ''the company'') and highlighted the need for an improvement of the company's business partner compliance process.…”