Friday, February 22, 2008

Commentary on SAP anti-corruption Wiki

I posted this on, but the wiki editor acted in unexpected ways, plus I found a typo which I can't edit, so I'm republishing the commentary here.

If you have access to SDN, here are links to the original topic:

My commentary

Much of what I have seen published on Corporate Social Responsibility & Sustainability (again, CSR for short) is from the perspective of a corporate entity. Thus, we see terminology such as:

  • provide practical guidance for companies to deal with
  • state this policy on your company website
  • train your personnel

Alas, most of us are not in a position to control or directly influence the above. We may work for a company and want to know what those policies are, or we may be shareholders (or prospective shareholders) and want to know if a company has such policies. What you could do is use the internet to find what a company has published. If it is easy to find, clear and unambiguous, all to the better. If it is hard to find, or just not there, it is time to follow one of my favorite bumper sticker slogans, "Question Authority!"

Full disclosure: I own (as of February 2008) 1 share of Federal-Mogul, a company recently reorganized out of bankruptcy triggered by lawsuits related to asbestos-bearing products such as automobile brake shoes.

I looked on the Federal-Mogul web site ( and after a short search, found information related to Financial Code of Ethics. On many corporate web sites, public statements related to responsibility are found in Investor Relations or similar places, because most need to deal with Sarbanes-Oxley and other legal requirements. While this is important data, it doesn't directly relate with corruption issues.

Looking further, I found paths to:

Home > Investors > Corporate Governance > Code of Ethics


Home > Investors > Corporate Governance > Code of Ethics > Integrity Policy

This is more related to the ethical questions around bribery and corruption. The web content was rather meager, but I found a link to a PDF document entitled "Integrity Program for Federal-Mogul Employees." I'm not an employee, so I might have skipped that, but being a stockholder, I was interested in what management was communicating to employees. Right up front, I found the media contacts that I could use to ask questions on topics that were unclear or not covered by this document. For comparison purposes, does your company, or companies you work with, share information such as this:

Reporting Integrity Issues
If you have a complaint or concern about Federal-Moguls accounting, internal controls, auditing matters or would like to report a violation of the Federal-Mogul Integrity Policy, you may call 800-368-4338 (outside North America and Puerto Rico, call 770-582-5258) at any time 24 hours per day, 7 days a week, or write to: Federal-Mogul Helpline, The Network c/o 5015, 333 Research Court, Norcross, GA 30092.

Myself, I'd like to see an email address, or a web page to report questions, but toll-free numbers plus street addresses are good enough.

In this 30+ page document are chapters "Working with Customers and Suppliers," Fair Competition," "Your Personal Integrity," etc. On the specific concern about gifts and hospitality, these tips are listed:

  • Could it harm Federal-Moguls reputation?
  • How would my actions or choices appear to others?
  • What would my family or friends say?
  • How will it come across when presented by the media?
  • Should I make sure?

And, then in more detail, the following:

Never offer or give anyone a bribe, kickback, illegal political contribution or other improper payment. Use good judgment to avoid even the appearance of an improper payment. Make sure business entertainment is lawful, reasonable and permitted by the policy of both your customer and Federal-Mogul. Employ reputable people, and require sales representatives and other third parties to comply with this policy. Follow the laws of the United States and other countries that relate to these matters.

Never offer or provide anything of value to a customer or government official to influence or reward an action (refer to Foreign Corrupt Practices Act, p. 16). Never offer or accept a business gift or entertainment if it could create even the appearance of impropriety.

All good, clear, and helpful information.

But then I saw this on page 12 under Working with Customers and Suppliers, Following International Trade Controls:
What to watch out for:

  • ...
  • Requests for information related to the Arab boycott of Israel

As a stockholder, this is where I would stop and write to management to ask for a clarification of this policy. It seems there is something unwritten here, where management is trying to prevent employees from taking political stances, but not being an international trade lawyer, I have no idea how a request for information is harmful.

The main point of this example is to show that corporations have ethics policies, they are likely to be found on their web sites, and that employees, stockholders, partners and consumers can be more informed with a bit of research.

[All opinions expressed here are mine, not my employers, customers, suppliers or partners. Well, maybe some of Kathy's are here ]

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