As a global architectural, engineering and design company working in high-risk industries such as construction and extraction, and often in countries exposed to high corruption risks, Ramboll needs to have a robust anti-corruption management system in place.
Acting honestly, decently and responsibly is a fundamental part of Ramboll’s values. We comply with anti-corruption laws, including the UK Bribery Act (UKBA), the US Foreign Corrupt Practices Act (FCPA) and follow local laws in every country in which we operate.
Some of our key risks for corruption in our projects can include non-transparent bidding processes, obtaining public permits and approvals, and managing our supply chain.
Ramboll takes a pro-active, zero-tolerance stance against corruption and bribery, as well as anti-competitive, antitrust and monopoly behaviours, such as price fixing and cartels.
Our Anti-Corruption Management System builds on five strategic building blocks covering the Global Compliance Programme: Leadership & Organisation, Policies & Controls, Training & Communication, Risk Assessment and Monitoring & Reporting. These building blocks drive implementation of anti-corruption through a strong top management commitment, operational controls, continuous training of management and employees in our anti-corruption policy, and due diligence of business associates. In addition, we have established grievance mechanisms that enable our employees and external stakeholders to raise concerns of misconduct. In the development of our Global Compliance Programme and efforts to reach our ambitious target of demonstrating best industry practice, we apply the guidance from the UKBA and FCPA legislation, as well as anti-bribery management system standards such as ISO 19600 and ISO 37001, and OECD guidelines on anti-corruption.
Ramboll’s Global Compliance Programme is designed and implemented by a mature compliance organisation, and we have launched a new Charter for the Group Compliance Function describing Ramboll’s compliance governance and mandate as delegated by our Group Board of Directors. As part of securing a mature compliance organisation, we have been preparing for a new regional compliance governance across Ramboll, which will take effect in 2020.
- Carry out global implementation of compliance onboarding videos.
- Ensure continuous focus on automated compliance controls.
- Fully implement new regional compliance governance structure.
- Carry out global implementation of new compliance risk assessment for business associates.
Assessing corruption risks in the business
Corruption and bribery risks are continuously assessed throughout our business. Anti-corruption is an integrated part of Ramboll’s Enterprise Risk Management process. However, our greatest risks are in our projects, and therefore our Global Project Integration Tool (Pi Tool) has been designed to identify and flag compliance risks for Project Managers when they assess project opportunities. If compliance risks are flagged based on input from the Project Managers, Group Compliance is involved to conduct risk assessment and recommend mitigating actions to be implemented as part of the project management. During 2019, some of our key efforts have been to enhance our compliance risk support to projects and continuously improve the existing controls in our project management tools. Furthermore, we have been developing a new process for conducting compliance risk assessment of business associates that enhances our risk-based approach.
Finally, to address risks related to sponsorships and donations, a global Sponsorship and Donation Guideline has been developed and will be implemented in 2020. We have also developed on-boarding videos within compliance and anti-corruption for all new employees to supplement current local compliance on-boarding activities and customised face-to-face anti-corruption training for selected employee groups.
In 2019, 159 compliance concerns were reported to the Global Compliance organisation, including whistle-blowers. This is an increase from the number reported in 2018 (82). The development is considered a result of maturing compliance activities and a sign of a healthy speak-up culture in line with international benchmarks. Following investigations of the reports, 70 (44 per cent) were substantiated (compared to 47 / 57 per cent in 2018) and appropriate mitigating actions have been taken. Learning from compliance concerns is important when ensuring the continuous improvement of policies and procedures. During 2019, our internal investigations procedures have been enhanced, meaning that from 2020 a new risk classification for compliance concerns will be introduced to ensure improved governance of internal handling.