You recent won an award from the Institute of Risk Management. Why is winning this award important to you?
Thank you and I have to say it is something we are very proud of. The truth is that, any organisation that wants to compete on the world’s stage must ensure that it has robust and effective risk and governance structures and for us being part of the wider global network that is Diageo and being listed on the US and UK exchanges means that we have to hold ourselves to those standards in addition to what might obtain locally.
The impact of non-compliant behaviors or not having effective compliance structures in place can be disastrous for a company just like ours, with operations in about 180 countries.
The recent high profile GSK bribery allegation is a life example on what noncompliance to internal policies as well as external regulations can do to a company’s reputation. Other companies like Danone, HSBC, Barclays Bank, Tesco, etc, have also had their share of public and regulatory scrutiny on various issues bothering on good corporate governance, which has in one way or the other affected their corporate reputation. Reputation is key to the success of any business enterprise.
Which is why at Guinness Nigeria Plc., we strive to demonstrate the highest standards of integrity in the way we behave towards each other and to those outside of the company.
Our actions and interactions with our consumers, customers, employees, public officials, suppliers, shareholders and other stakeholders clearly reflect our commitment to doing the right thing. Reputation is critical to our commercial success and can only be enhanced by behaviors of which we can all be proud.
How is your organisation structured to cope with the increasing global demands for ethical business practices?
We have a Code of Business Conduct and Ethics which applies to everyone working for Diageo (our parent company) worldwide regardless of location, role or level of seniority. We expect those who work with us and for us to act in accordance with the principles of the Code and relevant policies and standards.
The Code sets out our commitment to conducting business in accordance with our purpose and values, all relevant laws and regulations and industry standards.
It provides guidance on what is expected of each stakeholder and references other policies and standards. Failure to comply with the Code, policies or standards is treated very seriously and may result in disciplinary action, up to and including dismissal.
We have a fully resourced compliance and ethics office whose main responsibilities are the inculcating of our values, Code of Business Conduct and Global Policies in the organization.
They have different strategies that they deploy to ensure that compliance and ethics remains in the front of mind of all employees, because as you may be aware a well-executed ethics and compliance program can eliminate a significant amount of improper behavior.
We walk the talk in terms of our compliance programme. Within two months of joining the organization employees have a one on one formal compliance and ethics induction.
As a stop gap between when they resume and when they have their induction, a mandatory onboarding is done within 7 days of resumption, which is followed by an online Code of Business Conduct training. The formal induction class is a reassurance that the new employees are on the same page with rest of the organization.
The tone at the top is very vital in the effective compliance programme in any organisation; as such we have a line manager capability tool kit which invariably enhances our line managers to respond to the enquiries of their direct reports with agility.
We also have an annual ethics and compliance programme tagged “Pathway of Pride” where we as a company dedicate a month to discuss issues bothering on compliance and ethics, including ethical dilemmas that we face every day in the performance/execution of our job roles and responsibilities.
The 2014 edition was recently concluded in April 2014. We have 15 global policies which all Diageo companies are expected to comply with. Some of these policies include: Anti money Laundering Policy, Anti-corruption Policy, Anti-discrimination & Human rights policy, Employee Alcohol Policy, Quality Policy, Environmental Health and Safety Policy etc.
We also have an annual certification of compliance which is a platform on which employees are tested on their appreciation of our code of business conduct and our global polices.
How do you influence your business partners and how do you ensure that they imbibe your values?
We have a robust Know Your Customer and Know Your Business Partners Programme. Before we engage the services of any business partner it is mandatory to conduct comprehensive due diligence on them, in addition to this, each vendor has to provide comprehensive information about the company in the procurement Vendor Education Package, and a mandatory certification of compliance with our Code of Business Conduct and all applicable laws including the Foreign and Corrupt Practices Act (FCPA).
We also periodically conduct trainings for our business partners on our Code of Business Conduct and other salient policies.
Our business partners are aware that we have a zero tolerance to all forms of unethical behaviours/activities in relation to our business. We are constantly reviewing our business relationships to be sure we are engaging in business relations with like-minded companies/individuals.
How do you intend to shape the ethical sphere in corporate Nigeria?
We are a member of the executive core group of the Convention of Business Integrity (NGO), which is an NGO with the key objective to provide an alternative to the perceived all-encompassing culture of corruption, showing that there are other ways of behaving / doing business in such a highly-corrupt environment.
We were platinum sponsors of the First Christopher Kolade Lecture on Business Integrity, we are also on the board of the Anti-Counterfeit Collaboration (ACC )- Nigeria’s flagship anti-counterfeit group, to mention a few.
We share our Code and the accompanying policies with our stakeholders, and do not compromise on any of our values.
We continuously keep focused on the high expectations we have set and allow others to understand how we operate and how they can adopt, refine or build on our experience. Our expectations are high but with the right partners, we can redefine the conventional. Together, we will drive systemic change.
We have periodic trainings with our business partners where we explain our code and our salient policies, and the reasons why we cannot follow the “norm” in some instances.
They are encouraged to cascade these values to their own business partners and employees as well. We endeavor to consistently walk the talk and live our values in spite of the challenges of doing business in our environment. Though, to be sincere, it can be tough at times, but we are relentless in our pursuit of conducting clean business in Nigeria.
How can your ethical culture be a competitive advantage for businesses in Nigeria?
Employees are more satisfied at companies with reputations for ethical business practices and good governance, and as such Guinness continues to be an employer of choice. Investors are better educated now, and are actively seeking for ethical companies where they can invest.
By acting ethically, we have a greater opportunity to outperform our peers and win in the marketplace, whilst attracting technical partners who are seeking ethical businesses to align with.
Building positive reputation is strategic to any corporate organisation; especially a global brand like Guinness, the success of any business pretty much depends on its public image, which also helps to build consumer loyalty.
Finally, our ethical stance, and compliance structure will invariably build on our reputation and our global ambition to create the Best Performing, Most Trusted, and Respected Consumer Products Company in The World.