COHERENCE AND EMBEDDING

Building a culture of integrity requires a sustainable and targeted approach.

The efforts must reinforce one another. Ideally, the organisation has an integrity plan that is regularly evaluated by the Management Board and supervisory directors.

The Management Board may appoint an integrity officer – compliance officer, ethics officer or integrity coordinator – who monitors coherence within the integrity policy, identifies risks and coordinates, monitors and adjusts those efforts.

Many different functions within the organisation are involved in integrity. This does not only concern the integrity officer, but also, for example, HR, the secretary to the Management Board, procurement and legal affairs. The Management Board would be well advised to identify all integrity actors, or have them identified. Who is working on ethics? The organisation can form a collaborative integrity team.

TIPS FOR SUPERVISORY DIRECTORS

  1. Inquire after the integrity policy/infrastructure and the evaluation of how it operates.
  2. Discuss how integrity governance is organised. For example, is there a portfolio holder on the Management Board and/or the Supervisory Board? Or, is integrity a shared responsibility? Both approaches have advantages and disadvantages. Also, consider the extent to which safeguarding integrity factors into discussions that the Supervisory Board, in its role as employer, has with the Management Board member.
  3. If no integrity officer has been appointed, discuss the desirability of doing so. Otherwise, invite the integrity officer to a Supervisory Board meeting to share their experiences and to report on the integrity policy.
  4. Evaluate what role the Supervisory Board has, or has had, in safeguarding integrity. For example, are explicit provisions on integrity included in the Supervisory Board regulations and, if so, are they being complied with?