Policies and Standard Operating Procedures (SOPs) for Corruption Prevention, Conflict of Interest (CoI), and Code of Ethics have a central role in maintaining the integrity and transparency of an organization. These policies and SOPs are a vital foundation for regulating behavior, minimizing risks, and building an organizational culture of integrity. Publish What You Pay (PWYP) Indonesia realizes that the accountability of civil society organizations is important. This can be seen from how the organization addresses conflicts of interest, ensures anti-corruption practices, and builds an organizational culture of integrity. PWYP Indonesia considers creating internal policies and SOPs in these three areas essential. PWYP Indonesia can maintain institutional integrity, minimize risks, and ensure honest and responsible operations in the long run.

On November 20, 2023, PWYP Indonesia held an internal workshop, “Developing Corruption Prevention, Conflicts of Interest, and Codes of Conduct Policies for Civil Society Organizations”. Present as resource persons, Winarso and Dadang Trisasongko from Mercof, who introduced the Anti-Bribery Management System (ABMS) based on ISO 37001:2016.

The workshop opened with the sparking question, “Does a person of high integrity guarantee that the organization they lead will be an organization of integrity?”. Every organization has a natural risk of fraud, both high and low. Some organizations with a high risk of fraud or bribery are usually comprised of many individuals, have a wide range of work areas, manage large budgets, and operate in specific sectors such as natural resources, law enforcement, finance, or the arms trade. While personal integrity is essential, it does not guarantee integrity in an organization, as oversight of individuals is often very limited.

Winarso presents the benefits of ISO 37001:2016 implementation on bribery prevention. This system controls management in detecting, following up, and preventing bribery within the organization. ISO 37001:2016 becomes a tool to build the organization’s reputation in the eyes of business partners, government, and other stakeholders, both at national and international levels. In addition, this system is also proof of the organization’s compliance with local regulations. It protects against exposure to the “corporate liability” article in the Anti-Corruption Law (UU) in case of a violation or suspected bribery in the organization. As a result, organizations that implement and are certified in ISO 37001 are considered to have a low risk of bribery. In this session, Winarso provided the stages of implementing ISO 37001:2016 and the preparations.

A discussion and consultation with Dadang Trisasongko on a number of draft organizational policies followed the workshop. The drafts are the Anti-Corruption Prevention policy, the Conflict of Interest (CoI) policy, and the Code of Ethics. This is also crucial in building a solid foundation for an organization or entity to fight corrupt practices. Dadang also facilitates the exchange of ideas, adding in-depth knowledge and practical experience to formulate effective and comprehensive strategies to prevent and address corruption cases in organizations. The workshop covered policy formation and the implementation, monitoring, and evaluation aspects needed to ensure the success of the anti-corruption efforts implemented. The involvement of Dadang, who is also a member of the PWYP Indonesia’s Board, and the active role of PWYP national secretariat members in this policy planning discussion can provide a solid foundation, increase awareness, and encourage a strong commitment to integrity and values in an organization.

Author: Ersya Shafira Nailuvar
Reviewer: Aryanto Nugroho