Operating a telecommunications organization with professionals from various fields, without a compliance program is like walking a high wire without a safety net. There are many benefits that a compliance program brings to any organization.
A compliance program promotes an organizational culture that encourages ethical conduct and a commitment to compliance with the law. At IHS, compliance with the law and policies is everyone’s responsibility.
The primary objective of compliance is to provide direction, guidance, and resources to optimize ethical and compliant behavior. The compliance unit in IHS conducts the day-to-day compliance activities which includes:
1. Helping to identify and implement best practices to ensure excellence in fulfilling IHS's legal, ethical, and regulatory obligations.
2. Developing and implementing policies and procedures.
3. Promoting training and communication about compliance activities.
4. Monitoring the performance of each department’s functions for compliance with best practice standards, policies, and legal and regulatory obligations.
5. Identifying and addressing deficiencies and recommending improvements.
6. Periodic assessments to establish compliance program priorities.
It is imperative that we read and understand the IHS Code of Conduct and its accompanying policies, this will greatly provide clarity when faced with unethical issues. Sometimes we do the right thing and it is intentionally misconstrued, how much more if we intentionally do something bad. I will cite an example
There was an instance where a staff was offered money by a consultant who represents one of IHS’s landlords. Having understood what the company stands for, the staff declined the money and reported the issue to the compliance unit. We in turn reached out to the consultant and had an intensive and educative training session with them. Weeks after this training had occurred, we had the pleasure of meeting with the landlord for a different matter, and the landlord mentioned casually that IHS’s employee benefitted from the rent money that was paid to the consultant. The look of horror and shock could not be hidden on the faces of the IHS staff that were in attendance. The Head of Compliance spoke up and informed the Landlord that no such thing happened. He informed those present of what transpired between the consultant and our staff. Fortunately for us, the landlord informed us that the consultant was on the premises and was summoned to the meeting room.
The consultant was dumbstruck and could not alter accusatory/defensive words toward us. Apparently, the bribe that had been offered to the IHS staff was pocketed by the consultant, who in turn lied to the Landlord that we took the money that was offered.
The lesson to be learnt from this scenario is that despite the malicious lie against the company we were able to defend the company’s reputation and value. We may have never been presented with this rare opportunity to defend the company’s reputation and strong value.
This would have had a negative effect on the company’s public image and brand.
Imagine an FSE who is on his way to perform a preventive maintenance check on a site is stopped by policemen, community thugs or area boys. If all the necessary documentation for the vehicle is presented and the policemen still insists on a bribe “something light”, at this point you are being extorted.
What we advise in this situation is to get as much information about the policemen, their station and even up to the level of getting the plate number of the police vehicle. Kindly provide the requested amount to the policemen and immediately report the incident to the legal team or the regional counsel.
The Legal department is more equipped, trained and experienced in dealing with law enforcement agencies (especially the corrupt ones) than you are, they will handle the situation and will endeavor to ensure that all illegalities are treated and reported. They can even get the money extorted from you returned.
Most of these dilemmas would not arise if as a company we do the right thing, on time, the first time, all the time. As staff of IHS it is imperative that we:
1. Read the IHS Code of Conduct and Compliance Policies
2. Understand the IHS Code of conduct and Compliance Policies
3. Read communications sent out by the Compliance Unit
4. Participate in the e-learning training and
5. ASK!!!ASK!!!ASK!!!! No question is insignificant
If you are ever faced with a dilemma and are not sure of how to handle it, please ask and seek clarification from your line manager or Head of Department. If they are unable to resolve the issue to your satisfaction, please meet with the compliance unit or any member of the legal department.
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