Meeting and exceeding legal and industry standards in a constantly changing environment is an essential part of DHL Freight's mission to shape our customers' supply chains responsibly. This is why we work with Transparency International, for example. In this interview, two compliance experts, Dr. Anna-Maija Mertens, Managing Director of Transparency International in Germany, and Dr. Sofia Halfmann, Senior Vice President, Compliance and Export Control Officer at DHL Global Forwarding, Freight, talk about how important cooperation between NGOs and companies is in fighting corruption worldwide.
What is the relationship between DGFF and Transparency International?
Halfmann: Transparency International is instrumental for any compliance officer whose agenda includes the fight against corruption. We are both on the same side, so it makes sense for us to work together. Transparency International also publishes a wealth of research material, in particular the Corruption Perceptions Index, which is an invaluable resource. I have been using it for over 20 years and regularly present it in training sessions and risk assessment workshops. I hope that the collaboration between TI Germany and DGFF will intensify, and we will work even closer together in the near future.
What does Transparency International stand for as an organization?
Mertens: Transparency International is THE global anti-corruption organization. We have an ambitious vision – a world free of corruption – and our mission is to be the game changer in terms of implementing legislation to set the rules of anti-corruption. We are globally active, with about 110 chapters in all regions of the world. This is essential because corruption is contextually and culturally driven, and therefore takes different forms in each place, which requires different solutions to fight it.
Halfmann: This global coverage is something I highly appreciate. It may be easy to fight corruption in say New Zealand or Denmark, but having these organizations in countries where it is difficult, where corruption is still endemic, that is where TI can really put its foot down and lobby for strong and essential reforms.
How important is it for TI to cooperate with global companies like DGFF?
Mertens: It is very important because, in Germany, there is not a lack of regulations, but a lack of proper implementation of these regulations. We need to work closely with global companies when we elaborate our recommendations, because they are the ones who will have to implement them in the end. In doing so, we can ensure that these recommendations are feasible from a practical and business point of view.
Transparency International also works closely with politicians …
Mertens: Yes, we build a bridge between business and politics. If you have companies doing self-reporting about due diligence in their own supply chains and they say it is impossible to implement – as was recently the case in India – then we need to report this to political leaders. We need to ask: “Does it make sense that companies are checking their own partners, or should a state authority take the lead?” It is all about communication. It is not only bureaucracy and checklists.
What does Transparency International mean for you as a compliance officer?
Halfmann: You would be surprised how much of an impact the research done by Transparency International can have. You can talk about corruption, the laws, what people should and should not do, etc. but it is only when you show them the Corruption Perceptions Index map, that the importance of it really strikes them. It is absolutely an eye opener for senior managers and other colleagues in the organization.
Where do you see the biggest risk for corruption at the moment?
Mertens: We have recently seen that corruption can be driven by crisis. Germany, which is low on the CPI, has been affected by it as well. Remember the mask scandals last year. Lobbying – the interaction between politics and business – is a very important part of political decision-making as it ensures that different parts of society are heard. However, this should also be made transparent. It should be guaranteed that each and every interest group that is relevant to the topic is heard and all the facts are on the table. Nonetheless, this can fall behind when there is a crisis. Processes are shortened to act fast, in particular due diligence processes. That is what we saw with the mask scandal. We try to tell political leaders not to shorten due diligence processes. It always ends up taking more time, costing more money, and in the end can cause reputational damage.
Customs clearance is a high corruption risk for DGFF in many countries. What have you done to ensure that the zero-tolerance policy is carried out?
Halfmann: As customs brokers for our customers we need to be excellent and fast. We cannot wait, because every delay means goods sitting and accumulating demurrage fees and blocking space in a warehouse. Hence, we are dependent on government officials, customs authorities and customs officials to clear goods and to do this as soon as possible, and they know that. In countries that do not have an electronic customs clearance system, we even need to collect signatures or stamps, and make sure goods are transitioned through this process in person. That is why, we rolled out the Customs Interaction Excellence Project (CIEP) to assure full compliance in our customs clearance processes globally.
What did that involve?
Halfmann: We went into all countries, with a focus on those deemed to be at a high risk for corruption, and took several actions. We made sure there was no cash involvement, and that every payment to customs authorities was fully receipted and legitimate. We trained our employees and senior management and got them certified. We talked directly to customs authorities and ensured their support of our efforts to fight corruption. Every clearance process is a local regulation, so some of the actions were individualized by country. In the end, it was very successful. It also helped clarify and enhance the quality of our customs clearance process because the less gaps you have, the less mistakes you make – and the fewer times authorities can step in and block shipments. We’d rather compromise on profit, but never on compliance.
How do new business trends such as ESG and sustainability roadmaps support the anti-corruption agenda?
Mertens: It is certainly an opportunity. We talk a lot about the E and the S, but the G is often missing. I would love to change the order, because you need to deal with G first in order to have good procedures. We need to talk more about how the E, S and G support each other, how they are interconnected, and who guarantees we have the same criteria and same monitoring system in place.
What is the DGFF perspective regarding compliance and ESG?
Halfmann: I fully agree with Anna-Maija. The governance should be first and then you can worry about the technical content portion. I believe that publicity around the topic is helpful, but we need to be mindful that this doesn’t become a check-the-box activity. We should avoid coming up with KPIs to do KPIs.
Mertens: That is a very good point Sofia. When we talk about the regulations, we very often stay in line with what is being asked for, or follow the bureaucracy and technical obligations we are asked to fulfill. Instead, we should talk more about the intention of the legislation: Why do we have it? We need to continually talk about what we actually want to achieve and ensure the tools are not being misused.
Do you see compliance as a competitive advantage?
Halfmann: Yes definitely, and more and more so. Our customers don’t just expect it, they also do due diligence on us. We don't have a patented product that the world needs like pharma companies do. Just as our competitors, we ship from A to B. So what distinguishes us is our quality of service and part of that is compliance: We don't get our customers in trouble, we support them. In some difficult countries, especially in countries where the CPI scores are very low, our sales colleagues actively use compliance to sell our services. In fact, in our recent internal Compliance Awareness Week, we had a panel discussion where participating customers confirmed that if they have the choice between price and compliance, they would always go for the service provider that has a good compliance program in place.
What drives you to support abolishing corruption?
Mertens: I am a political scientist and an institutionalist, so I'm passionately interested in processes and structures. To be part of a global movement is also great. I am originally from Finland, now working in Germany, and this mixture is already very interesting. When it gets even broader, it is huge! To see that we are, at the end of the day, able to change the world, is absolutely fantastic.
Halfmann: I want to support our employees in putting their foot down and making changes globally by telling government officials or others that corruption is not OK and that it has detrimental effects on societies. No one likes corruption – at least when you’re the victim of it. There's still a lot to do, but overall, I think, when I started the journey in the compliance area 20 years ago it was definitely worse. So there is room for hope and as part of DPDHL we can all make a difference.
Berlin based Transparency International was founded in 1993 and is active in over 110 countries. Its purpose is to end the injustice of corruption. Through its advocacy, campaigning and research, TI works to expose the systems and networks that enable corruption to thrive, demanding greater transparency and integrity in all areas of public life. There are three main benefits for companies to join Transparency International Germany:
- Guaranteed exchange: Before TI talks to politicians about what is needed in terms of new legislation and laws, it talks to its members, listens to their arguments and concerns.
- Confidential peer learning: Members have the opportunity to talk about cases, and failures, and learn from other experts.
- Fast track to all materials: Members are the first to know about new reports and research, which they can then use in their daily business.