SENSITIVE ROLES

INTEGRITY RISKS AND THE IMPACT OF VIOLATIONS

The consequences of a violation can be serious, which is why organisations have a major responsibility to promote integrity across the board and to help prevent violations as much as possible. In this way, they protect both their own organisation and their employees and others involved. It is important for an employer to keep sight of broader measures that concern all employees and the entire organisation, such as a reporting procedure, code of conduct and the deployment of confidential advisers. In addition, employers must also pay attention to the individual. After all, every integrity violation can ultimately be traced back to an act or omission by one or more individuals, even when those individuals are acting as part of a larger collective.

PROCESSES VERSUS THE INDIVIDUAL

This brochure focuses on risk management in the field of integrity. Identifying and assessing risks at process level is the most common approach in this area. We take individual employees as the starting point and look at integrity risks at role level. By focusing integrity policy on employees, the employer fulfils its responsibility to practice good employment*. This enables employers to take more targeted control measures and strengthen the resilience of both the organisation and employees against integrity risks.

The impact of an employee’s integrity violation depends, among other things, on the extent to which that employee can cause harm in their role. After all, embezzlement by an employee who is authorised to manage a company’s business accounts can potentially cause more financial damage than embezzlement by an employee who has no direct access to business accounts.

It is difficult to predict whether an employee will misuse their powers or the resources made available to them by the employer in the future. The intention is not for employers to regard all employees as untrustworthy from the outset or to approach them with suspicion. This can negatively impact the organisational culture. However, it is often possible to identify vulnerabilities that increase the risk of an integrity violation. Sometimes these vulnerabilities lie within the organisation itself, such as neglecting the four-eyes principle, or applying it incorrectly. At other times, they stem from personal employee issues, for example when the employee has financial problems. It is in the interests of both the organisation and the employee for the employer to identify, acknowledge and address these vulnerabilities as much as possible. The next chapter uses an action plan to explain how employers can do this.

* Section 7:611 of the Dutch Civil Code.

The employer and the employee must behave as befits a reasonable and fair employer and a reasonable and fair employee.