B20 ITALY

Integrity & Compliance

Policy Paper 2021

TABLE
OF CONTENTS
Foreword by the Taskforce Chair

5Remarks from the Taskforce Co-Chairs

6

Executive Summary

7

Recommendation: Summary

10

Introduction

13

Recommendation 1: Responsible conduct throughthe Procurement Cycle

16

Context

19

Policy Action 1.1: Improve the efficiency of public administrations

22

Policy Action 1.2: Enhance and implement digitalization for public 		administration processes

23

Policy Action 1.3: Foster integrity and transparency throughthe Procurement Cycle

24

Recommendation 2: Sustainable governance in business 26
Context

29

Policy Action 2.1: Stimulate the implementation of a sustainable 		2

Governance31

Policy Action 2.2: Assess ESG performances

33

Policy Action 2.3: Improve integrity and compliance in supply chains34

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Recommendation 3: Cooperative compliance models
and rewarding systems
Context

36
39

Policy Action 3.1: Promote public-private cooperation to enhance 		
compliance40

Policy Action 3.2: Corporate compliance efforts in private sector

41

Policy Action 3.3: Protection of whistle-blowers

42

Recommendation 4: Beneficial ownership Transparency
Context

45
48

Policy Action 4.1: Adopt technology to ease access to Beneficial 		
Ownership information

51

Policy Action 4.2: Develop digital public national registers

52

Policy Action 4.3: Enhance power and independence of authorities

53

Annex

54

Key Performance Indicator

56

Schedule of Taskforce Exchanges

58

3B20 POLICY PAPER INTEGRITY & COMPLIANCEB20 POLICY PAPER INTEGRITY & COMPLIANCE

Foreword by the Taskforce Chair
Reinterpreting integrity and compliance“Compliance and integrity-based programs are the leading pragmatic approaches to ethics, which is key in today’s business environment. The concepts ofintegrity and compliance are taking on a broader scope, which in a momentof unprecedented challenge, with very severe socio-economic consequences, islinked to the idea of sustainable business. Therefore, companies are called upon
not only to pursue the profitability of their investments, but to integrate further
interests to promote virtuous synergies and positive impact among stakeholders.
In this sense, adopting, promoting and rewarding cooperative compliance efforts through the use of effective supporting technologies and digital solutions
that improve the overall quality of work and wellbeing of individuals is key.
Companies with a strong ethical culture enhance their ability to attract investors, customers and talented professionals. The foundations of ethical behavior start at the top of the pyramid and allow companies to create a culture thatvalues integrity.
The COVID-19 pandemic has turned into an acceleration of the emergence of
global risks, penalizing our economies, social unrest, climate changes, and social
inequality. Therefore, the strong commitment of the B20 Italy is to convey andtransmit the new role of organizations and the need to recognize the centralityof the human factor in business, providing pragmatic solutions to embrace andredesign a new path focused on inclusion and making a positive impact to create
a better future.”
Sincerely,
Patrizia Grieco
Chair of the B20-Taskforce on Integrity and CompliancePosition of Taskforce Chair

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Foreword by the Taskforce Co-Chairs

Katja Bechtel

Lead, Partnering Against
Corruption Initiative(PACI), WEF

Michele Crisostomo
Chair, Enel

María Fernanda
Garza Merodio
CEO, Orestia

Klaus Moosmayer

Member of the Executive
Committee and Chief
Ethics, Risk and Compliance Officer Novartis

Niansha XU

Chairman of China
Poly Group Corporation

6"As we emerge from the COVID-19
pandemic, businesses will play a key role
in rebuilding societies and economies
with integrity.
A holistic approach to sustainable
governance as well as Collective Actionthat leverage emerging technologies formore integrity and transparency are
indispensable for a just and sustainable
recovery."“Integrity and adequate anti-corruption
tools are critical to the credibility andeffectiveness of the post COVID-19
recovery efforts.
A sound compliance system, embedded
in a sustainable governance framework,
along with public-private cooperationand transparency are essential to ensurea fair and proper use of funding”.

“The business of business is no longer
just the business itself. Society will only
gain substantive ground on the fightagainst corruption and the challenges
presented by the ongoing pandemic
through public and private sector joint
efforts such as the ones proposed by theB20 ACWG”.

“As businesses, we must emerge fromthe current pandemic with an evenstronger commitment for integrity andcompliance.
We call for Collective Action with the
G20 and all of society, to facilitate
joint and sustainable governance andintegrity standards for both the private
and public sector”.

“Recommendations regarding integrity
and compliance have been adopted inmany previous B20 summits. Consensus
has been developed as well.
Pursuing integrity and compliance has
not only encouraged enterprises to create
economic value for mankind but has also
played an increasingly important role infostering social progress”.

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Executive Summary
The Italian Presidency of the B20 intends to support multilateral institutions
and instruments, directing them towards precise "key" objectives, such as accompanying major transitions, both ecological and digital, strengthening theresilience of the economic systems as well as their ability to mitigate inequalities and characteristics that have been severely tested by the pandemic crisis.
In addition, the B20 considers fundamental all measures which aim at strengthening integrity and compliance, and that are also oriented towards developing fair competition in the business production as a whole, from manufacturing to services.
Policies and actions linked to the macro themes of integrity and compliancecan bring a significant contribution to these objectives, acting both directly on the private sector and through cooperation between the private andpublic sector. In this sense, the Task Force has been an example, also due toits adoption of a sharing method undertaken with the G20 Anti-Corruption
Working Group. This confirms the overriding interest of businesses in operating in an environment with a high level of freeness, integrity and sustainability, which is a prerequisite for achieving sustainable development goals.
Moreover, the severe economic crisis generated by COVID-19 has intensified
and expanded the various forms of public intervention in economic systems.
In this context, to combine effectiveness in the use of public funds with theneed to contain the risks of corruption and other illegal practices, gets increasingly important. In the opinion of the Task Force, the latter should becomea real benchmark for setting procedures - authorization and control - for theoperation of recovery plans approved by public authorities.
The Task Force of I&C Policy Paper builds on the above-mentioned assumptions, while also taking on a broader view over the traditional integrity andcompliance perimeter. The document intends to pose particular attention
on two key themes:- the fight against illicit behaviour and malpractices to improve integrity inpublic administration. This paper proposes actions to increase transparency
and efficiency, especially in sensitive areas, such as public tenders and the
management of financial flows, by promoting transparency and efficiency,
which can now make use of digital 'levers', as well as cooperation with theprivate sector which can be found in compliance programmes and high-level
cooperation initiatives (e.g. Collective Action) as a reference point;- the promotion of sustainable governance in business, which builds on acommitment to legality and the fight against corruption, thus enabling themto reshape processes to incorporate Environmental, Social and corporate
Governance (ESG) objectives into corporate compliance. Moreover, such ameasure will positively contribute in fostering a better balance between shareholder and stakeholder value and providing more effective 'governance' ofsupply chains.
In this context, the paper also considers some cross-cutting “dynamics”: i) the
impact of the pandemic crisis on addressed issues; ii) the leading role thatlarge enterprises, included State-Owned Enterprises (SOEs) can play with regard to the evolution of governance systems in ESG terms; iii) the importance of broadening Small-Medium Enterprises’ (SMEs) business opportunities,
also through virtuous functioning of supply chains, while also increasing benefits for competition; iv) the need to develop agile initiatives in response to7

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new and emerging corruption risks, including sector specific ones, like thosearising in sport and health.
The first Recommendation ("Responsible conduct through the procurement
cycle") contains, first of all, proposals which aim to promote efficiency in public decision-making processes, through the strengthening of "administrative
capacity" which, in turn, depends on - among other things - the effectivenessof the systems of selection and training of officials in charge of managing
tenders. Digital tools can be of great support, as they contribute to increasing
the transparency of processes while also reducing the number of "contacts"
occasion, which could potentially lead to opportunities for corruption. Also
procedural simplification should be accompanied by an adequate degree ofdigitization in order to maintain a strong level of supervision and controls
over such processes. Moreover, another essential element is the "leverage"of Collective Action, such as integrity pacts, i.e. initiatives through which theprivate sector undertakes commitments that go beyond what is required bylaw, in order to address specific situations of vulnerability identified in collaboration with public actors.
The second Recommendation (“Sustainable governance in business”) contains proposals which aim to ensure that the corporate governance contributes to the achievement of sustainability objectives. In concrete terms, measures such as risk assessment and corporate governance choices must now
be able to promote an evolutionary process that combines the ability to remunerate shareholders while creating value to stakeholders. In this context,transparency is a key factor, especially when it comes to the dissemination of
non-financial reports, which must be based on uniform standards at global
level. Of equal importance, is the ability of supply chain managers to monitor
integrity standards along the supply chain, as well as acting as role models fortheir contractors and suppliers, first and foremost through contractual "leverage", for example compliance programs, codes of conduct and/ or contract
clauses, as these are the tools best suited to the structures, capacity and of
SMEs.
The third Recommendation ("Promote public-private cooperation to enhance compliance") focuses on the development of compliance models andrewarding systems. It contains proposals to strengthen the link between theeffectiveness of such cooperation and the dissemination of programmes andmeasures to combat illegality and corruption. It also highlights the centralityof reward mechanisms, such as leniency programmes and, again, Collective
Action, also in terms of disseminating best practices of public-private cooperation. To make both risk mapping and the enforcement of compliancemodels effective, whistle-blower protection systems should be considered as
an essential component. Those systems should also be encouraged in consideration of the use of digital tools, implemented in such a way as to combine
a ban on any form of discrimination against whistle-blowers with the protection of the identity and position of whistle-blowers.
The fourth Recommendation ("Beneficial ownership transparency") is dedicated to beneficial ownership and anti-money laundering policies. It contains
proposals aimed at strengthening: actions on the transparency of beneficial
owners, through the standardisation of the standards adopted on a global
scale; the effectiveness of information exchange mechanisms; the accuracyof public registers and their accessibility by the Control Authorities. In thiscontext, technology is now a crucial variable in ensuring both the quality andthe easy availability of the data contained in the registers, as shown by thegood practices already implemented at global level. At the same time, additional efforts are still needed from Governments, both for the creation and8

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proper maintenance of the registers, a process in which the so-called gatekeepers can contribute, and to strengthen the prerogatives of the Control Authorities, whose cooperation is a key factor in combating criminal practices
associated with money laundering.
Finally, for the first time, the Task Force will introduce indicators in the formof Key Performance Indicator (KPIs). We truly believe that KPIs are essential
to measure the policies that the B20 intends to suggest, in order to assess
and act on the basis of progress made, or detected shortcomings, by future
B20 Presidencies.

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Recommendations: Summary
Recommendation 1: Responsible conduct through the Procurement Cycle
Public procurement plays an important role in achieving the SDGs and responding to COVID-19 threats. The pandemic and the emergency procedures that have been adopted to address it have exacerbated the inherent risks
in the procurement cycle, e.g. complex bidding processes, and the inevitableclose interaction between public officials and the private sector. It is more
important than ever to increase transparency, integrity, and accountability
throughout the procurement cycle and to leverage emerging technologies
to prevent and detect instances of corruption, thus creating a more competitive and inclusive process by encouraging fair and equitable competition.
Policy Action 1.1: Improve the efficiency of public administrations – The
efficiency within public procurement systems contributes to lowering therisk of bribes made to expedite the performance of public officials of anon-discretionary nature, i.e. which they are already bound to perform, also
in cases of discretionary decision-making. Indeed, the efficiency starts withprofessionalized civil servants, working pursuant to ethical standards, withina well-designed institutional framework. It is also important to focus on technologies and policies that report procurement data in real time, crowdsourcing watchdog functions, and increasing stakeholder engagement andaccountability throughout the procurement cycle. In this respect, building
a strong synergy with the business ecosystem is key for the realization of amore efficient public administration.
Policy Action 1.2: Enhance and implement digitalization for public administration processes – Digitizing administrative processes to reduce manual intervention improves the efficacy of audit, compliance monitoring andcontrol activities in detecting irregularities. In order to maximize and leverage a digital transformation process, fostering cultural change and building
capacity in the skills required to manage open and digital platforms is key.
To increase the digitalization in the public sector it is necessary to train theworkforce along with allocating sufficient resources for the development ofinnovative digital systems, since the infrastructure within government organizations is often insufficient. E-procurement systems are one of the mosteffective digital tools as they reduce manual interventions and improve theefficacy of audit activities in detecting bidding irregularities, particularly
when designed in conjunction with the Open Contracting Data Standard(OCDS). In this context, the implementation and adoption of digital tools canease access and participation of SMEs in public tenders. Moreover, Collective
Action activities involving businesses can build technical capacity to manage
open digital platforms and maximize the impact of these transformations toensure they reflect a broader commitment to sustainable governance andcultures of integrity in both the public and private sectors.
Policy Action 1.3: Foster integrity and transparency through the Procurement Cycle – It is important to adopt high-quality standards of integrity andcompliance programs by enabling timely access to public information andenhancing enforcement and supervisory authorities. Further, designing andimplementing effective systems such as High-Level Reporting Mechanism(HLRM) to facilitate reporting of potential corruption concerns, facilitates
SMEs participation.
Recommendation 2: Sustainable governance in business – Compliance cansolidly support companies to better evolve towards organizational models
that are more sensible and respectful with regards to stakeholders' values
surrounding sustainability. In this sense, corporate governance plays a rele10

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vant role, fundamental to the operating continuity of any corporation, andsimilarly, sustainability emerges as a key element in synergy with compliance.
Policy Action 2.1: Stimulate the implementation of a sustainable Governance – Raising the bar of compliance among organizations while defining
how sustainability can become part of the compliance frameworks is key. In
this context, good and transparent corporate governance systems, to be defined by companies internally, which clearly articulate the roles, responsibilities
and accountabilities of the governing body, management and internal audit,
may attract investors that nurture interest in positive impact investing. Moreover, supportive measures in the implementation and promotion of good
governance practices in business are fundamental.
Policy Action 2.2: Assess ESG performances – Virtuously promote a culture of integrity, sustainability and positive impact among stakeholders within
the business, as well as among G20 countries, fostering the adoption of supportive measures such as non-financial reporting, with uniform requirements
across jurisdictions, to ease the assessment and mitigation of ESG issues.
Policy Action 2.3: Improve integrity and compliance in supply chains – Promoting and fostering the contribution to sustainable development by offering
training and guidance on Responsible Business Conduct (RBC), while encouraging the appointment by businesses of an Integrity & Compliance Officer- a senior level position with strategic importance that goes beyond core compliance - also functioning as a positive example to be emulated across the entire supply chain. Consideration should be given to design measures which arealso easily adaptable by SMEs capacities.
Recommendation 3: Cooperative compliance models and rewarding systems – Integrity and compliance should become milestones for organizations. In this context, there is a strong need to foster dialogue, enhance cooperation, trust and strategic alignment among public and private organisations,stimulating and rewarding voluntary management commitments, while considering the enrichment of the understanding of associated risk profiles through measures such as due diligence policies and third party risk management.
Policy Action 3.1: Promote public-private cooperation to enhance compliance – Reinforcing the concept of reward to foster collective trust in cooperative compliance efforts can be achieved through promoting the adoptionof rules, effective measures and inclusive cooperation to improve the exchange and availability of information among stakeholders from the private-publicworlds who aim to increase compliance and good conduct.
Policy Action 3.2: Corporate compliance efforts in private sector – Implementing due diligence policies within hiring companies and their supply
chain when selecting, monitoring, reviewing and auditing contractors, andmanaging associated risk profiles, supports SMEs in the due diligence of theircommercial partners (e.g. supporting the adoption of systems such as Global
Value Chain Passport). In this context, governments should consider providing incentives for companies to adopt compliance programs and implement
digital solutions.
Policy Action 3.3: Protection of whistle-blowers – Improving compliancewithin the private and public sector, reinforcing and rebuilding trust in public
and private institutions, through, for example, the adoption of effective andefficient whistle-blower reporting and protection systems supported by innovative communications technology. In this context, it is key to focus on therights of the person against whom a report has been made, the protection of
the reporting person as well as the freedom from retaliation.
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Recommendation 4: Beneficial ownership Transparency – To contributesolidly to the establishment of beneficial ownership transparency it is key
to fight anonymous shell companies that contribute to enabling corruption,
fraud, organized crime and tax evasion. Further, adopting supportive measures such as innovative technology to enhance access to high-quality data andinternational cooperation is vital.
Policy Action 4.1: Adopt technology to ease access to Beneficial Ownership information – Fostering the adoption of innovative digital technologies
allows information on beneficial ownership to be accessed and shared reliably.
Policy Action 4.2: Develop digital public national registers – Increasingtransparency around beneﬁcial ownership information, improving third-party risk management and ensuring the accuracy of data stored in digital national public registers is key.
Policy Action 4.3: Enhance power and independence of authorities – Consistently promoting the sharing of up-to-date information regarding legal arrangements, preventing the misuse of bearer shares and nominee shareholders or directors, while fostering companies’ support with creating fairness
through a set of common rules and standards levels the playing field.

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Introduction
The concepts of integrity and compliance are taking on a broader scope,
which in a historical moment marked by the emergence of new global risks, islinked to the idea of sustainable business.
In the current landscape impacted by the effects of the COVID-19 pandemic
on communities and the economy, integrity and compliance risks have been
aggravated well beyond the healthcare sector. The increased risk of fraud
and misdirection of public funds and the vulnerability of emergency procurement processes call more than ever for a stronger alliance between public
and private sectors to reinforce the overall resilience of the political, institutional and economic systems.
Therefore, this situation is an unparalleled opportunity to place a renewed
focus on combating corruption, strengthening integrity and enhancing transparency while reinforcing global solidarity.
Business environment plays an essential role for boosting the recovery phaseand for supporting the fight against future global crisis. As acknowledged by
the previous Presidency, it is notable that over past months many businesses
have also intensified public communications regarding their commitment tothe societies where they operate, emphasizing responsible business conduct.
Indeed, B20 members intend to develop and disseminate a new vision ofcompliance. The essence of the message comes from the introduction of acontemporary holistic approach to integrity and compliance which aligns
with other key themes such as human rights, anti-corruption and bribery
matters, and sustainability.
The two concepts of compliance and integrity can thus be unbundled andread independently and complementarily. Following this route, the concept
of integrity could encompass themes such as transparency, accountability
throughout the public procurement lifecycle, implementation of codes ofconduct (or otherwise contractual clauses) in B2B relationships, and internalreporting systems to protect those who highlight procedural violations.
Within this framework, the fight against corruption clearly remains a top priority for the G20 and the B20. It is of utmost importance to continue promoting the adoption and enactment of key anti-corruption principles andinternational instruments, such as the United Nations Convention Against
Corruption (UNCAC) and the Organization for Economic Co-operation andDevelopment (OECD) Anti-Bribery Convention. B20 members also welcome
the G20’s increased emphasis on implementation and accountability as set
out in the G20 High-Level Principles for the Development and Implementation of National Anti-Corruption strategies.
This policy paper builds on past G20 initiatives in this matter and it is alignedwith the objectives of the Anti-Corruption Working Group (ACWG) Action
Plan for 2019-2021. Also, B20 members underline that the policy paper has
been developed taking into account current ACWG work, and in particular
the ongoing elaboration of the new three-year ACWG Action Plan, as well as
the envisaged G20’s High-level Principles on Corruption-related Organized
Crime, in the light of the higher risk of criminal infiltration in a post-pandemic
scenario. This Task Force also acknowledges the G20’s efforts to take stockof member countries’ activities concerning the measurement of corruption,
while recognizing the crucial role of business sector in this exercise and its
willingness to actively give a contribution.
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Against this background, B20 members have chosen to call for a stronger
commitment from the G20 on four key areas: (i) ensure a responsible conduct
through the Procurement Cycle from both companies and governments; (ii)stimulate sustainable governance in business while focusing on standards’
harmonization; (iii) adopt – as much as possible – a uniform approach to legislative initiatives, so as to ensure a level playing field for companies operating
in and across the G20 countries, and promote cooperative compliance models and rewarding systems; (iv) enhance beneficial ownership transparency.
These recommendations have been shaped considering both the remarkable
work by previous G20 presidencies and the need to respond to the specific challenges posed by the acceleration of the COVID-19 crisis and by the
ambitious global challenges facing the business world. Accordingly, for each
recommendation, B20 members have developed concrete and measurable
policy actions that deserve urgent consideration.
The new idea of compliance that B20 members strongly support also reflects
a solid intention of creating an ecosystem where companies are called upon
not only to pursue the profitability of their investments, but to integrate further interests into promoting virtuous synergies and positive impacts among
stakeholders. Thus, with a view to fostering the above combined approach,emphasis will be put on an overall greater policy coherence and alignment
with international instruments, such as the United Nations Guiding Principles on Business and Human Rights and OECD Guidelines for Multinational
Enterprises. In this respect, voluntary instruments should be mentioned, suchas the Ten Principles of the United Nations Global Compact on human rights,
labour, environment and anti-corruption.
With the support of the G20, the B20 can significantly contribute to theachievement of Sustainable Development Goals (SDGs). The B20 recommendations and suggestions have been put together taking into account thenecessity for embracing and promoting actions in favour of achieving SDG
objectives’, especially with regards to goal #1 No Poverty, #5 Gender Equality, #8 Decent Work and Economic Growth, #9 Industry, Innovation and Infrastructure, #10 Reducing Inequality, #11 Sustainable Cities and Communities, #12 Responsible Consumption and Production, #16 Peace, Justice, andStrong Institutions, and #17 Partnership for the Goals.
In this moment of unprecedented challenge, with severe socio-economic
consequences, B20 members call the G20 to support the efforts of companies, organizations and institutions on reinforcing and maintaining their controls, systems, governance and appropriate integrity culture in adjusting to
the new realities of COVID-19. This includes the strengthening of the international cooperation and the establishment of appropriate risk-assessment
activities related to the next phase of the pandemic, i.e. the recovery, vaccination and post-vaccination, as well as of clear rules and procedures to provide legal and compliance certainty to companies that intend to give support
in case of similar potential devastating events.
To this end, the pandemic has also functioned as an accelerator of the digital transformation, involving the expansion of geographic market boundaries
and of supply and sales chains. This phenomenon also implied an amplification of existing risks such as fraud, misconduct and compliance, leaving space for a constantly incremental need to promote and reinforce integrity andtransparency.
For these reasons, B20 call for time-bound implementation and reiterate
the importance of measuring national and collective progress on the implementation of all previous and future G20 commitments as well as public

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reporting back on advancements. The involvement of key stakeholders suchas the business community in the evaluation of progress made against suchcommitments could be an added value. Therefore, B20 members offer full
support in the implementation of those commitments including the Anti-Corruption Action Plan, through public-private partnerships and Collective Action. Similarly, the increasingly interconnected global economy provides
more opportunities for criminal networks engaged in illicit markets – such ascounterfeits, trafficking in persons, wildlife, narcotics and excise goods. Illicit
trade, like corruption, impedes economic growth and sustainable development efforts, generating considerable losses of economic value and affecting
not only government revenue, but also multiple legitimate business sectors
and citizens exposed to sub-standard and dangerous products¹.
The above concepts of integrity, compliance and sustainable business supported by the B20 are all fundamental pillars for contributing to the achievement of the priorities of the Italian G20 Presidency, expressly putting at thecentre of the common reflection people, prosperity and the planet.
Exhibit 1
All I&C topics link back to the
SDGs and Italy’s G20 principles

Figure 1 - Preliminary assessment: SDGs per topic identified: #1, #5, #8, #9, #10, #11, #12, #16, #17; - Italy’s I&C TF
analysis¹ B20 Italy, Recall to Task Force Trade and Investment - Recommendation 2: Policy Action 2.2, 2021

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Recommendation 1: Responsible conduct through the Procurement Cycle
One of the most vulnerable activities affected by corruption is public procurement, representing almost the majority case of bribes’ and one of themost recognized high-risk areas for corruption in governments². The main
reasons for this include the volume of transactions and financial interests aswell as the complexity of the processes, the close interaction among public
officials and businesses, and the multitude of stakeholders involved. Within
this moment of unprecedented challenge, there is the necessity to align with
the G20 Principles for Promoting Integrity in Public Procurement to reinforce administrative prevention systems to detect cases of corruption to protect the integrity of the financial and public contracts systems. COVID-19
has created vast and varied integrity challenges, especially for governmentsin the area of public procurement³. Explicitly, the pandemic has solidly contributed to creating an obligatory condition for governments to make quick
decisions and implement drastic measures to protect communities at risk,
while also limiting economic consequences that might follow. Since the beginning of the pandemic, public procurement and other services (e.g. licensing and permitting) are facing a significant risk of corruption as traditional
checks have been minimized by the applied emergency procedures. Therefore, it is fundamental for businesses to pay particular attention to public
integrity, which is a key component in presenting a resilient response to thecrisis, ensuring that government action benefits those in need⁴. Multi-lateral
institutions are facing similar procurement risks; thus it is important that thesame standards of accountability and transparency are upheld. The digitalization of the public sector is a driver of change in the integrity field. Technology innovations powered by data and behavioural insight are disrupting
corruption risks and boosting integrity systems. They are accelerating new
forms of accountability based on the smarter exploitation of big data andfostering new public and private partnerships for integrity. In the digital era,
data has become a critical asset for integrity actors to detect and deter fraudrisks, complex networks and corrupt practices. Advanced analytics and artificial intelligence (AI) can raise red flags and early warnings in high-risk transactions and suspicious financial flows in seconds by cross-referencing public
databases and big data. At the same time, predictive analytics can pinpoint
vulnerabilities and pre-empt risks. When combined with insight from behavioural science they help devise more targeted buffers against fraud⁵. To thisend, it is important to promote the OCDS and ensure alignment with the
G20 Anti-Corruption Open Data Principles. Furthermore, it could be beneficial to provide organizations with a clear set of rules and procedures aimed at
reinforcing lawfulness and compliance in conducting business during periodsof crisis. Therefore, in this context, it is fundamental to constantly review andupdate national anti-corruption strategies and plans, with a view to increasing the effectiveness and coordination of anticorruption initiatives and measures, and to reflect specific learnings gained during the pandemic.

² OECD, Preventing Corruption in Public Procurement, 2016
³ UNODC, COVID-19 Vaccines & Corruption Risks: Preventing Corruption in the Manufacture, Allocation andDistribution of Vaccines, 2021
⁴ OECD, Public integrity for an effective COVID-19 response and recovery, Updated 19 April 2020
⁵ WEF, Hacking Corruption in the digital era: How tech is shaping the future of integrity in times of crisis, May 202016

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Policy Actions
1.1

Improve the efficiency of public administrations – The efficiency within public procurement systems contributes to lowering the risk of bribes made to expedite the performance of public officials of a non-discretionary nature, i.e., which they are already bound to perform, also incases of discretionary decision-making. Indeed, the efficiency starts withprofessionalized civil servants, working pursuant to ethical standards,
within a well-designed institutional framework. It is also important tofocus on technologies and policies that report procurement data in realtime such as crowdsourcing watchdog functions, increasing stakeholder
engagement and accountability throughout the procurement cycle including after award. In this respect, building a strong synergy with thebusiness ecosystem is key for the realization of a more efficient public
administration.
• The G20 should promote and enhance “good performance” withinpublic administrations, where its actions must also converge and be adequate to achieve desired results.
• The G20 should encourage investments in adequate training andselection of public officials engaged in procurement, licensing and permitting, and increase technical and managerial capacity to effectively
define tenders in terms of project requirements, scoring models andparticipation criteria.
• The G20 should improve transparency, accountability, and time effectiveness as well as broadening participation and responsiveness within public institutions. It is important to focus on streamlining and simplifying the public procurement system and its institutional frameworks,
while contributing to wider sustainability goals and social value considerations.
• The G20 should promote a more effective management of publicfinances resources through the adoption of specific sets of laws, rules,
penalties, systems and processes aimed at mobilizing revenues, allocating public funds, undertaking public spending and accounting for funds
and audit results.
• The G20 should promote advanced accounting reforms in the public-sector, due to their position at the forefront of the global application of accrual accounting, while considering the adoption of International Public Sector Accounting Standards.

1.2 Enhance and implement digitalization for public administration processes – Digitizing administrative processes to reduce manual intervention improves the efficacy of audit activities in detecting irregularities
and helps to better prevent and counter corruption, including duringcrises. In order to maximize and leverage a digital transformation process, it is imperative to foster a cultural change and build capacity ofavailable staff with the skills required to manage open and digital platforms. Moreover, digital tools can also facilitate access and participation of SMEs in public tenders.
• The G20 should promote the digitalization of administrative processes to increase transparency and accessibility. Artificial Intelligence,
contract analytics, and RPA - Robot Process Automation, can reduce un17

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necessary interactions with public officials, decreasing opportunities forcorruption.
• The G20 should stimulate the analysis of public databases and increase the accessibility of them through new technologies to identify
patterns of behaviour capable of bringing to light red flags and high-riskareas.
• The G20 should foster the implementation of effective training andsolutions which improve attractiveness while stimulating employee turnover to increase flexibility and progression towards better integrationand transition with digitalization.
• The G20 should support the redefinition of procedures and services
in a digital perspective, providing that other administrations and civil society have access to data and services related to specific operating areas
and activities of public administrations.
1.3 Foster integrity and transparency through the Procurement Cycle
It is important to adopt high-quality standards of integrity and compliance programs by enabling timely access to public information. Open,structured, standardized data formats such as the Open Data Contracting Standard align closely to the G20 Anticorruption Open Data
principles; and by enhancing enforcement and supervisory authorities
design and implementation of effective systems such as HLRM, reporting of potential corruption concerns in addition to SMEs participation
can be facilitated.
• The G20 should encourage public institutions to draft bidding, licensing and permitting criteria and use procurement tools such as Request
for Proposal (RFP) software to provide up-to-date market intelligenceso as to facilitate SME participation in government procurement in a
cost-effective, accessible and flexible manner.
• The G20 should use open and competitive bidding, encourage faircompetition, and increase transparency, ensuring the publication of relevant tender documentation including on the authorization and controlof emergency procedures, to improve information sharing and accessusing effective and innovative digital technologies.
• The G20 should develop Collective Action to identify specific vulnerabilities, promote the development and implementation of effective
compliance programs and areas of potential exposure within the procurement cycle, encouraging further guidance on what public authorities
can do to prevent and detect bribery internally.
• The G20 should adopt procurement integrity tools, such as Integrity
Pacts and market consultations to ensure competitive bidding criteriathat maximize public value and facilitate the participation of SMEs aswell as women and minority-owned businesses.
• The G20 should stimulate the design and implementation of HLRM,
to encourage stakeholders to effectively address complaints of bribery
solicitation and related practices involving public officials, while improving transparency. Additionally, it is key to enable accountability of theofficials/parties (public and private) involved in corruption through dissuasive sanctions.

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Key Performance Indicator
The B20 Integrity & Compliance Taskforce proposes that current and future G20 presidencies monitor progress on the Global Corruption Index. The
proposed KPI, as inserted below, shows the relative ownership, the given baseline and the 2024 target ambition.

Global Corruption Index

Owner: GRP
Baseline
46%(2020)

Target40%(2024)For further details please see the relative Annex.

SDG impacted - 8: Decent Work and Economic Growth - Promoting
integrity and efficiency in public administration to facilitate private investments and stimulate economic growth. 9: Industry, Innovation and Infrastructure - Ensure responsible business conduct through the procurement
cycle to ensure ethical conduct in infrastructure projects. 10: Reduced Inequalities - Foster integrity in public procurements, reducing corruption in
public expenditures, decreasing inequality by affecting income distribution.
11: Sustainable Cities and Communities - Implement efficiency in public
services to the benefits of local communities. 16: Peace, Justice and Strong
Institutions - Promote and reinforce anti-corruption systems, to build effective, accountable and inclusive institutions. 17: Partnerships for theGoals - Promote synergies among the private and public sector, enhancing
efficiency, cooperation, innovation and responsibility.
Italy's G20 principles - People: Ensuring responsible conduct through theProcurement Cycle to contribute towards the fight against corruption. A
high level of perceived corruption may negatively impact the experiencesof human beings, threatening the human rights, political, economic, socialand cultural aspects of an ecosystem. Prosperity: Higher corruption levels
are associated with lower levels of innovation. In this context, corruption solidly and negatively affects the overall development of a system, impacting
the prosperity and potential progression of countries, businesses and societies. Corruption also compromises the quality of the procurement outputs
whether it is public assets' integrity, or the efficiency of the public services
provided. Planet: Sustainable public procurement has become a key point
for countries and authorities, playing a fundamental role in sustainable development. Governments are responding with unprecedented spending in
response to the pandemic to ensure the implementation and adoption of
public procurement mechanisms that do not harm people and the planet. To
this end, enhancing integrity and efficiency in public procurement may positively contribute to the achievement of the Sustainable Development Goals(SDGs).
Context
As previously mentioned, one of the most vulnerable activities impacted bycorruption is public procurement, one of the most recognized high-risk areas
for corruption in governments.

⁶ OECD, Preventing Corruption in Public Procurement, 201619

B20 POLICY PAPER INTEGRITY & COMPLIANCE

Some of the main reasons for this include the volume of transactions, thefinancial interests, the complexity of the process, and the close interaction
among public officials, businesses, and the multitude of stakeholders. In addition to public procurement other services such as licensing and permitting
serve as a significant risk area for corruption, closely tied to pandemic response and recovery.
The impact of corruption goes beyond the corrupt individuals who are implicated, or the reputation of the organizations they work for. Corruption may
substantially erode trust in the public sector to act in the best interests ofcitizens, contributing to wasting public resources that have been earmarked
for important community projects, resulting in poor quality services or infrastructure. Corruption is a key global phenomenon that represents a cost that
distorts competition and impacts on the economic development of nations.
The World Economic Forum estimates the global cost of corruption is at least$2.6 trillion, or 5 per cent of the global gross domestic product (GDP)⁷.
COVID-19 has put unprecedented strain on our economies and public finances, increasing the risk of corruption and fraud in addition to heightening
the need for public services. Countries such as Ecuador adopted solutions
to reduce corruption in public procurement by creating the Ecuadorian procurement agency SERCOP, a public search tool with downloadable OCDS
data, which lists the details to monitor COVID-19 emergency procurement,
detecting signs of corruption, and providing a channel for complaints. Civil
society identified overpriced contracts for key medical supplies and generated public pressure to suspend processes and hold responsible actors toaccount⁸.
The civil society as a whole, alongside internal audit, are both valuable forces
to strengthen controls over the procurement process.
Exhibit 2
The situation in the world

Perception of corruption in the world - The Corruption Perception Index (CPI), calculated annually by Transparency International, aims to measure the perception of corruption in different countries around the world.
This assessment takes a value from 0, for very corrupt countries, to 100 for countries considered not very corrupt.
In such context, it is important to mention the work by the G20 Anti-Corruption Working Group for the definitionof a brand-new index to measure corruption which revolves around objective criteria.

Economic impactof annual corruption

5%

World Gross Domestic
Product

Figure 2 – Transparency International, Corruption Perception Index, 2020
According to 2020 CPI ranking, New Zeeland with a score of 88/100 is ranked as the country with the least perceived levels of corruption (highlighted in blue within the figure above).

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Therefore, in this context, it is crucial to implement and adopt effective andimpactful measures to ensure a responsible conduct through the Procurement Cycle, in order to effectively fight and mitigate corruption phenomena⁹.
Moreover, at a general level, it is key to highlight that the availability of data
is a precondition to understand and thus tackle corruption. In fact, the topic of measurement of corruption has been recognized as a priority for the
G20 Anti-Corruption Working Group agenda. To this end, it is fundamental
to ensure that the business community will take part into the involved activities. Debate has developed surrounding the need to improve data collection
activities using sound methodologies, bearing in mind that measuring corruption is extremely challenging. Data on reported cases of corruption sufferfrom a high “dark figure”, because victims or witnesses are usually less likely
to report corruption cases than other types of crime. The lack of data was
one of the most recurring gaps identified by the Mechanism for the Review
of Implementation of the UNCAC.
The need to improve measurement methods has cbeen recently acknowledged by the Conference of the States Parties to UNCAC through the adoptionof the Resolution 8/10 ‘Measurement of corruption’. In the view of a morecomprehensive assessment of corruption, the Resolution outlines the importance of improving the measurement of corruption through comprehensive,
evidence-based and multifaceted efforts to detect and measure corruption-related trends. Further, the importance of developing an international statistical framework for measuring corruption, grounded in objective
methodologies and reliable data sources is imperative. UNODC consider theuse of direct methods on the experience of corruption the most reliable approach to producing the detailed information on corruption necessary forpolicymaking purposes.
Focus - Measurement of corruption
Different approaches to measuring corruption are discussed in detail in the Manual on
Corruption Surveys (UNODC, UNDP and UNODC-INEGI). The Manual classifies the various approaches to corruption measurement into direct and indirect methods as follows:
Indirect methods of measuring corruption, in which the measurement is not based on
the occurrence of the phenomenon of interest but is rather based on perceived levelsof corruption. Indirect methods can be based on expert assessments (where a selectedgroup of experts is asked to provide an assessment of corruption trends and patterns
in a given country or group of countries) or composite indices, combining a variety ofstatistical data into a single indicator. Several indirect assessments of corruption havebeen produced so far (including the Transparency International Corruption Perceptions
Index; Control of Corruption Indicator of the World Bank Governance Indicators; andthe Global Integrity Index);
Direct methods of measuring corruption aim to collect evidence-based information on
corruption through statistical and standardized procedures. They measure actual experiences of corruption rather than perceptions of corruption, and can include official dataon reported cases of corruption from a variety of sources (police, prosecutors, courts,
anti-corruption agencies) and experience-based sample surveys which allow for the direct collection of data on the experience of representative samples of a given population,such as households or businesses.

⁹ United Nations Office on Drugs and Crime (UNODOC), UNCAC Article 9, 2004
¹⁰ UNODC, UNDP and UNODC-INEGI, Manual on Corruption Surveys. Methodological guidelines
on the measurement of bribery and other forms of corruption through sample surveys, 201821

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Policy Action 1.1: Improve the efficiency of public administrations
Efficiency within public procurement, licensing and permitting systems contributes to lower the risk of bribes made to expedite performance of duties
which the public officials are already bound to perform. In this context, building a strong synergy within the business ecosystem, e.g. private sector andnon-profit organizations, and providing for a discipline of liabilities for Public Sector coherent with private sector, can strongly contribute to the realization of a more efficient public administration¹¹. This therefore demands
better resource allocations and reduces duplication through the adoptionof a specific set of rules, systems and processes, to mobilize revenue, allocate public funds, account for funds and audit results, while considering the
primary relevance of investments in carefully training and selecting public
officials. This entails ensuring that the public procurement system is basedon the principles of transparency, competition and objective criteria in decision-making. To this end, such a system can contribute to the achievementof more efficient public procurement and public administration, while also
setting clearer expectations for businesses and reducing possibilities for errors and corrupt practices. The implementation and adoption of high-quality accrual accounting standards in the public sector can contribute to lower
incidences of corruption. Finally, it is also important to focus on technologies
and policies that report procurement data in real time such as crowdsourcing watchdog functions, which involve a group of people to participate in areporting task (such as newsgathering, data collection or analysis through atargeted, open call for input, personal experiences, documents or other contributions), while also increasing stakeholder engagement and accountability
throughout the procurement cycle. In this perspective, taking all necessary
measures to ensure the full, equal and meaningful participation of women in
the development and implementation of relevant anticorruption activities in
the public and private sector is key.
Exhibit 3
International Civil Service
Effectiveness Index (InCiSE) 2019

InCiSE 2019: Overall country ranking - The International Civil Service Effectiveness Index (InCiSE) can be used as
an accountability tool which allows citizens, government officials and politicians to analyse civil service's performance.
••

It helps understanding the efficiency of public administrations, which is one of the main mitigating factors in
the fight against corruption.
It helps identify an index or a parameter to try to break down social gaps among countries around the world.

In this context, it is evident that there are large discrepancies between developed and less developed / emerging
countries, highlighting the need to bridge the gap and level the playing field creating or reinforcing transparent
and ethical rules and standards, thus mitigating corruption phenomena.

Figure 3 - Institute for Government analysis of International Civil Service Effectiveness Index (InCiSE), 201922

B20 POLICY PAPER INTEGRITY & COMPLIANCE

Policy Action 1.2: Enhance and implement digitalization for public administration processes
Digitizing administrative processes to reduce manual intervention improves
the efficacy of audit activities in detecting irregularities and reducing unnecessary interactions with public officials lessens opportunities for corruption.
The digitization of public services and administrative procedures should beseen as a priority to guarantee that these new digital tools are implemented
and adopted in an equitable manner, with an emphasis on least developed
emerging countries as a pivotal tool to foster transparency and accountability
in public sector processes. In such context, the digitization of administrative
process can also improve the results of due diligence when dealing with counterparty risk verification which focuses on information gathered from specificinformation providers and open sources. In some cases, such processes canbe further improved and strengthened by artificial intelligence mechanismsthat could ease the reconstruction of the control chain related to the potential counterparty, as well as in the verification of PEP/PIL List or other relevant reference lists and information. Furthermore, the implementation andadoption of effective and efficient digital tools will positively contribute to theaccess and participation of SMEs in public tenders. In order to make a digitaltransformation process more effective, it is equally fundamental to foster acultural change and build capacity, strongly considering the relevance of staff
availability and skills required to manage open and digital platforms by implementing dedicated training courses and improving talent attractivity. A keyrole can be played by e-procurement systems, which can improve the efficacy of audit activities in detecting bidding irregularities, particularly when
designed in conjunction with the OCDS. The previously mentioned Standard
enables disclosure of data and documents at all stages of the contracting process by defining a common data model. It was created to support organizations to increase contracting transparency and allow deeper analysis of contracting data by a wide range of users. Collective Action activities can build
technical capacity to manage open digital platforms and maximize the impactof these transformations to ensure a broader commitment to sustainable governance and cultures of integrity in both the public and private sectors.
Country Data – EGDI 2020 - The E-Government Development Index (EGDI) presents the state of E-Government
Development of the United Nations Member States. Along with an assessment of the website development patterns
in a country, the E-Government Development index incorporates the access characteristics, such as the infrastructure and educational levels, to reflect how a country is using information technologies to promote access and inclusionof its people.
•

Exhibit 4
E-Government Development
Index (EGDI)

Among the main composition of the EGDI measures, there are three key dimensions of e-government:- provision of online services;- telecommunication connectivity;- human capacity.

Figure 4 - UN E-Government Knowledgebase - EGDI 202023

B20 POLICY PAPER INTEGRITY & COMPLIANCE

The index is not designed to capture e-government development in an absolute sense; rather, it aims to give a
performance rating of national governments in relation to one another.

Policy Action 1.3: Foster integrity and transparency through the Procurement Cycle
Adopting high-quality standards of integrity and compliance programs byenabling timely access to public information and enhancing enforcement
and supervisory authorities with powers of inspection in order to comply
with RBC requirements through the procurement life cycle is critical. Moreover, the relevance of incentivizing responsible conduct through incorporating a standardized reporting framework into the tendering cycle aims at
capturing sustainability impacts has to be considered. In this regard, procurement tools and bidding criteria should also be designed in a cost-effective
manner, to be accessible and flexible, while also facilitating and incentivizing
SME participation. The promotion of private-public partnerships, codes ofconducts or sound compliance programs may also help to cope with the specific vulnerabilities and exposure emerging in the procurement cycle. G20
governments should leverage private-public partnerships to foster efforts inachieving greater integrity and transparency in the procurement cycle, whileremoving undue political influence. To this end, is of equal importance thattransparency also covers mechanisms like offsets, or ancillary services to beprovided before or after the award. The above-mentioned achievement canbe reached through sharing best practice on issues such as whistleblowing,
due diligence, oversight mechanisms, information disclosure and periodic assessments of corporate activities at risk. In this context, reporting preventive
measures aimed at tackling other integrity risks that may arise through thewhole procurement cycle plays a central role in consideration of the adoption of a more strategic approach (e.g., empowering procurers, leveraging
data-driven decisions) rather than just a legalistic one. To this end, it is also
relevant to mention best practices developed in private sector procurement,such as prioritizing transparency through planning and implementing strategic procurement policies, properly tracking every step of the process, andmaking frequent audit and centralized platforms. More clarity and guidance
will be needed on what public authorities, including internal organizations,can do to prevent bribery internally: establishing proper integrity and transparency safeguards in emergency procurement, licensing and permitting
processes is key to ensure that bribery does not impede fairness and effectiveness of public action and that conflicts of interest can be identified¹². Considerable relevance must be placed also in the design and implementationof a HLRM, a tool that aims to engage stakeholders to effectively addresscomplaints of bribery solicitation and related practices involving public officials, while improving transparency in a quick, cost-effective and practicalmanner. To this end, it is of upmost importance to enable accountability ofthe officials/parties (public and private) involved in corruption, considering
the adoption of measures like dissuasive sanctions. Similarly, it is key to engage in international cooperation and information sharing with other countries
to comprehensively address foreign bribery and related laws as an integral
part of the level playing field in global markets¹³, as well as promoting the useof effective asset recovery tools.

¹² OECD, The Directorate for Public Governance¹³ OECD, Foreign Bribery Enforcement: What Happens to the Public Officials on the Receiving End?, 201824

B20 POLICY PAPER INTEGRITY & COMPLIANCE

Integrity risks in the procurement process - In every phase of the procurement process, from the assessment ofneeds to contract execution and payment, there is a wide array of integrity-threatening risks. Clearly, the natureof the integrity risk may change depending on the specific phase of the process; specific red flags involve undue
influence, conflict of interest, and various kinds of fraud risks.

Exhibit 5
The integrity risks along the public
procurement cycle

Below is a brief overview of typical integrity risks throughout the Procurement end-to-end process.

Figure 5 - OECD, Integrity risks in the procurement process | OECD Preventing Corruption in Public Procurement, 201625

B20 POLICY PAPER INTEGRITY & COMPLIANCE

Recommendation 2: Sustainable governance inbusiness
There is a growing consensus that companies must go beyond mere compliance requirements to effectively address sustainable governance. Whenreferring to sustainable governance, the aim is to reach solid conditions for
implementing and ensuring that it can contribute to the achievement of sustainability objectives. Moreover, corporate governance choices must now
be able to promote a new concept that combines the ability to remunerate shareholders while creating value to stakeholders, having the capacity toeffectively do so in the future. As compliance issues are becoming broader
and converging with sustainability and human rights risks in business, an integrated and holistic approach to compliance is essential for companies tothrive in the long run. Today, being compliant with legislation and practices/
standards/policies have a twofold importance for companies. On the one
hand, it allows companies to achieve specific business objectives: improve
the reputation of the company, increase the confidence of its customers andstakeholders, and take preventive measures to avoid the risk of sanctions (civil, criminal and administrative). On the other hand, it protects fundamental
interests, such as the safety of workers and the environment, ensure the transparent management of financial and accounting flows, ensure technology isused correctly, foster protection of human rights across the supply chain while contributing to corporate responsibility. As recognized by the G20/OECD
Principles of Corporate Governance and the UNCAC, a sound compliancesystem is fundamental to help boards to embed sustainability into the business strategy of the company and to take into consideration the interests of
the relevant stakeholders. Therefore, a sound compliance system should also
relate to ESG standards, including corporate governance, health and safety,
human rights, environment, and countering financial crime and corruption.
The theme has been also reaffirmed during the COVID-19 crisis, reinforcing
the need for a solid RBC which encapsulates the concept of ESG and compliance efforts. Nowadays, in fact, an incremental relevance is leaning on the“G” factor of ESG. In this regard, ESG factors, should consolidate their positions as key components for organizations, dedicating leadership efforts
and resources in improving the effectiveness of their compliance programs
aimed to implement good practice integrity standards, by assessing the corporate culture, controls and governance from an integrity perspective. In
this context, it is also relevant to underline the roles of compliance - which ismainly conceived and motivated by legal obligations - and ESG standards whose implementation and adoption mainly rely on a voluntary nature andaim to fall into the compliance function. To this end, it is fundamental in fact
to underline that the commitment to ESG efforts, such as implementing sustainable governance, should always be conceived of a voluntary nature. In
consideration of the strong regulation, it will become more and more crucial
that compliance and ESG frameworks are understandable and comparable.
Explicitly, regarding ESG, it is fundamental to make sure that there is a solid
comparability, which comes from good, comparable, and trustworthy data.
In this context, there is already a strong perception on the proliferation ofdifferent standards, so to try to converge them into one overarching rulebook everyone can refer to is key. Moreover, it is relevant to build ESG frameworks that standardize non-financial reporting and align stakeholders on
what constitutes good governance. To this end, Collective Action activities
that engage multiple stakeholders are key efforts to protect market integrity,
encourage sustainable growth and protect the environment and human rights throughout global supply chains.

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Policy Actions
2.1 Stimulate the implementation of a sustainable Governance – Raising
the bar of compliance among organizations while defining how sustainability can become part of the compliance framework is key. In this context, good and sustainable corporate governance systems may attract
investors that nurture interest on positive impact investing. Moreover,the implementation and promotion of good and innovative governancepractices in large enterprises and SOEs are fundamental to create a positive leading example to be emulated.
• The G20 should promote the importance of value creation for companies, while considering and embedding values for stakeholder’s andcompany’s shareholders.
• The G20 should encourage the adoption of good and transparent
corporate governance systems including, for example, sound Enterprise
Risk Management and Business Continuity models, aimed at identifying
risks that organizations could face, forecasting the relevance of those risks in business processes, while also addressing the risks in a systematicand coordinated plan.
• The G20 should foster the contribution to increase accountability,transparency, responsibility and equitable treatment, within the organization’s decision-making process and compliance frameworks.
• The G20 should stimulate the implementation and promotion ofgood practices of sustainable governance in large enterprises and SOEs,
which should work towards maintaining their position as role models inthis field, contributing to enhance self-regulation while improving thequality of public services provided.
2.2 Assess ESG performances – Virtuously promote a culture of integrity,
sustainability and positive impact among stakeholders into the business,
as well as among G20 countries, fostering the adoption of supportive
measures such as non-financial reporting, with uniform requirements
across jurisdictions, while encouraging the assessment and mitigationof ESG issues. In this context, to support the initiative to rationalize andstandardize global system for sustainability-related reporting, including
through preliminary indications of national adoption, is key.
• The G20 should support the adoption of standardized non-financial reporting, to ease the burden on companies, to better evaluate thenon-financial performance of businesses and encourage companies
to develop a more responsible and transparent approach to business,through the support of several organizations which already have madeefforts in harmonizing ESG metrics.
• The G20 should encourage the systematic assessment and mitigation of ESG issues which can carry significant reputational and operational risks, such as credit access, public funds, insurance, etc.
• The G20 should promote and foster organizations to strongly contribute to sustainable development, focusing on human rights in linewith the UN Guiding Principles on Business and Human Rights and more
specific themes such as gender equality and diversity and inclusion, integrating them within their compliance frameworks and therefore throughout their organizational processes and policies.
27

B20 POLICY PAPER INTEGRITY & COMPLIANCE• The G20 should promote the assessment of sustainability requirements while performing due diligence activities. In this sense, ESG reporting and responsible business conduct should be considered as key
requirements before defining business relationships or investments tothe extent possible.
2.3 Improve integrity and compliance in supply chains – It is importantto promote and foster the contribution to sustainable development byoffering training and guidance on RBC, while ensuring any requirements
on supply chain integrity are as uniform as possible and preserve a level playing field for companies across G20 countries. To the same end,
G20 members should focus on the relevance of appointing an integrity& compliance officer. The role should be covered by a senior level position with strategic importance which also intends to look beyond corecompliance, functioning as best practice and as a positive example to beemulated through the entire supply chain, mainly with regards to largeorganizations. In this sense, there is a need to consider and design measures which are also easily adaptable by SMEs capacities.
• The G20 should promote the improvement of integrity and sustainability compliance, broadening the scope of application not only including national companies and multinational organizations but also their
suppliers.
• The G20 should promote the use of market power and contractual
measures, by the head of supply chain to the extent possible for a step-change in sustainability impact, as well as the capacity building among
SMEs and their supply chains by offering training and guidance on RBC.
• The G20 should encourage all companies with an emphasis on thoseat the top of supply chain to adopt and implement compliance programs(e.g. with codes of conduct and/or precise contract clauses concerning
integrity and sustainability), in order to stimulate RBC and act as rolemodels for their contractors / stakeholders and suppliers.
Key Performance Indicator
The B20 Integrity & Compliance Taskforce proposes that current and future
G20 presidencies, monitor progress on Business extent of disclosure indexand Governance Score.
The proposed KPI, as inserted below, shows the relative ownership, the given
baseline and the 2024 target ambition. The indexes range from 0 to 10, withhigher value indicating a more positive scenario.
The Business extent of disclosure index measures the extent to which investors are protected through disclosure of ownership and financial information.

Business extent of disclosure index

Owner: World Bank
Baseline
6(2019)

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Target6,43(2024)

B20 POLICY PAPER INTEGRITY & COMPLIANCE

Key Pilot Performance Indicator
The Governance Score relies on two key elements: executive capacity andexecutive accountability.
Although the index should be completed with all G20 members, the proposed
KPI, as inserted below, shows the relative ownership, the given baseline andthe 2024 target. Therefore, our ambition is to encourage governments to ensure continuous improvement of this indicator.

Governance Score

Owner: SGI
Baseline
6,4(2020)

Target7,1(2024)For further details please see the relative Annex.
SDG impacted - 1: No Poverty - Organizations may contribute to improving access to sustainable livelihoods, entrepreneurial opportunities, making sustainable investments and building productive resources. 5: Gender
Equality - Sustainability plays a key role in ending discrimination and empowering women which may strongly contribute to economic growth anddevelopment. 8: Decent Work and Economic Growth - Adopting good
and transparent corporate governance systems may attract investors that
nurture interest on positive impact investing, which contributes to economic growth. 9: Industry, Innovation and Infrastructure - Sustainable governance may focus attentions on making more investments in sustainableinfrastructure, increasing efforts surrounding scientific and technological research. 10: Reduced Inequalities - Sustainable governance can impact inequality reduction by reducing the gap of salaries of higher-level positions orredistributing welfare benefits and salaries to those on lower level position.
16: Peace, Justice and Strong Institutions - Effective governance could
positively impact on the sustainable development of peaceful and inclusive
societies. 17: Partnerships for the Goals - Good, accountable and transparent governance can promote better cooperation and therefore contributeto common goals.
Italy's G20 principles - People: Sustainable governance may have a substantial impact on the enhancement of positive and responsible behaviour.
Among some of the benefits that good governance may have on social ecosystems, we find the potential improvement of service effectiveness enhances
stakeholders’ satisfaction and foster citizens’ confidence in their government.
Planet: Sustainable governance may strongly contribute to the reduction ofnegative environmental impacts or disasters caused by wrong and irresponsible behaviour of human actions. Prosperity: Accountable, good and transparent corporate governance systems may attract investors that nurtureinterest in positive impact investing, contributing to the enhancement of theorganization’s reputation, focusing on a long-term perspective.
Context
In this period of unprecedent challenge and global socio-economic crisis,
how public and private organizations respond may prove to be the litmus test
for integrity. In fact, the concepts of integrity and compliance are taking on abroader scope, posing a necessity on changing priorities.

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The COVID-19 pandemic has accelerated the focus on global risks such as:
flaws occurring in critical infrastructures and public procurement cycles, assurance in procurement processes, cyber-attacks, social unrest, fragility of
economic systems and social inequality. A large number of managers andemployers believe that COVID-19 represents a risk to responsible businessconduct for their organization.
Therefore, there is an incremental need also to conceive and embrace new
ways of tackling emerging issues, which focus on the importance of governance as well as heightening the level of compliance among organizations.
The relevance of defining how sustainability can become part of the compliance frameworks is key.
Exhibit 6
Global investments in sustainability

Growth of sustainable investing over time - 2020 has been a record setting year for the growth in sustainable
investment; the global pandemic strongly impacted this topic, accelerating awareness and interest of investors
on ESG, considering the immediate and short-term impact that these practices imply. The following chart clearly
represents how the growth of sustainable investment has changed over the years, as well as how sustainable investing is becoming an unstoppable force with total assets doubling over the past seven years.

Figure 6 - BlackRock Sustainable Investing, with data from Broadridge and Simfund.
January 1, 2016 – September 30, 2020

Explicitly, compliance can help companies to better evolve towards organizational models that are more sensible and respectful with regards to stakeholders' sustainability interests. In this sense, sustainability and ESG are now
more important than ever, as for other themes such as diversity and inclusion. To this end, human rights are becoming a pivotal topic associated withcompliance, where it is increasingly important to promote synergies between
relevant topics within organizations, such as anticorruption and human rights. COVID-19 is testing our health, social and economic systems in extreme
ways. While facing extreme circumstances, people and organizations need tomake immediate decisions, considering the relevance of balancing responses
to the crisis in the short-term with maintaining resiliency to other risks facing
business and society in the long-term. Sustainability and ESG programs are
key elements of long-term value and business resiliency, however expectations on companies must remain realistic and should furthermore be considered in the context of the respective company characteristics, paying due
attention to the challenges that SMEs are facing, as well as in line with efforts
to foster recovery.
The current global scenario, where the pandemic is the protagonist, has revealed the importance of other non-financial factors that impact businessoutcomes and are important to ESG investors, such as disaster preparedness, continuity planning and employee benefits. In this context, there is also
an incremental relevance on non-financial reporting, which provides stakeholders with an important and comprehensive overview of the position
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B20 POLICY PAPER INTEGRITY & COMPLIANCE

and characteristics of a company's business activity on specific themes, suchas social, human rights etc. Some tangible steps that organizations shouldtake with respect to leveraging ESG and sustainability programs to build value in the short, mid, and long-term for all the business ecosystem are:•Set new priorities in order to take greater account of stakeholders’ interest;• Implement and adopt proactive measures to manage social and environmental risks across supply chains and organizations;• Embed sustainability in business strategy to manage and measure impacts that will support Long-Term Value creation.
Policy Action 2.1: Stimulate the implementation of a sustainable Governance
Heightening the level of compliance among organizations and defining how
sustainability can become part of the compliance framework is key. To pursue and effectively leverage the adoption and implementation of sustainable
governance, supportive measures can be considered, while taking into account the specific business contexts of different companies.
Beneficial initiatives for the above-mentioned implementation could be represented by efficient risk management measures – based on a comprehensive risk assessment¹⁴ – combined with corporate governance measures,
aiming not only to reinforce shareholder and stakeholder protection, but
playing a key role in leveraging ESG matters too.
It is also relevant to underline how adopting good and transparent corporate
governance systems may attract investors that nurture interest on positive
impact investing, contributing to the enhancement of the organization’s reputation as a whole.
Large enterprises and SOEs, due to their role and responsibility, should proactively contribute to implementing good and innovative governance practices, as their sustainable governance can positively influence the business environment and community¹⁵, granting them the chance to be seen as a rolemodel and thus being emulated by the business ecosystem.
While it is essential to foster G20 members in taking proactive steps in encouraging the above-mentioned enterprises to enhance their level of integrity and compliance, it is undoubtedly important to consider differences identifiable among enterprises and countries, posing particular attention when
detecting vulnerable situations.
Good governance within those enterprises is fundamental for efficient andopen markets at both levels, domestic and international, as they are often
considered to be the main providers of key public services. For example,
SOEs usually run complex businesses e.g. infrastructures and energy, which
are often involved in cross-border activities. Any action undertaken fromthem regarding ESG may have a significative impact: in this sense, the junction between public and private can really boost ESG development.

¹⁴ Recommendations in such context can be consulted within “UNODC United Nations Office on Drugs and Crime An Anti-Corruption Ethics and Compliance Programme for Business: A Practical Guide, 2013”, document built on
UNCAC and UN Global Compact publication on Anti-Corruption Risk Assessment and recommendations, which
also relates to carrying out due diligence requirements as set forth in OECD MNE Guidelines and OECD Due
Diligence Guidance for Responsible Business Conduct¹⁵ Transparency International, 10 Anti-Corruption Principles for SOEs, 2017
on the measurement of bribery and other forms of corruption through sample surveys, 201831

B20 POLICY PAPER INTEGRITY & COMPLIANCE

According to the above, it is equally clear how large enterprises and SOEs
hold a central role in the fight against corruption. In such context, a Collective
Action initiative has been developed during the B20 Presidency in Argentina
and also referenced in an exhibit in the B20 Saudi paper. Such initiative is theresult of a collaboration between the OECD and the Basel Institute whichhave developed the project “Compliance Without Borders”. Its main aim is
to facilitate professional cooperation between the public and private sectors
by developing joint initiatives¹⁶.
Explicitly, with reference to SOEs, research conducted by the OECD led tolong-established guidelines¹⁷ which are internationally noticed. G20 could
refer to the research when setting standards for how governments should
exercise the state ownership function. Overall, G20 members should concentrate on implementing high standards of ethics, integrity and compliance,
while also considering their role in sustainable corporate conduct and governance. In fact, it is of same importance to encourage the G20 to reinforce
efforts to implement the 2018 G20 High-level Principles for Preventing Corruption and Ensuring Integrity in SOEs.
Exhibit 6
Governance

Assessing governance level - Corporate governance plays a key role as it is fundamental to the operating continuity of any corporation. Companies trying to meet standards or regulations can find themselves in a minefieldas they navigate the areas of governance and compliance. Therefore, the need to establish governance and compliance around sustainability to manage risk is constantly growing. In this context good and transparent corporate governance can be seen as a success factor. In fact, some of the key benefits that may emerge as a result of theimplementation and adoption of effective good and sustainable governance include:•
Encouraging positive behaviour: It is fundamental that all board members are involved in the culture of
the organization, while ensuring clear lines of communication with management and with the organization. In thiscontext, having clearly delineated policies and processes and a board of directors and executive managers whotake an interest in such matters can strongly contribute to preventing future failures whilst positively participating
to a better understanding and setting the organizations cultural expectations;•
Increase trust: When stakeholders feel able to rely upon the information provided by companies this leads
to increased levels of trust, enabling organizations to develop stronger, longstanding relationships with their stakeholders;•
Enhances sustainability: A strong commitment towards implementing good governance also enables organizations to quickly identify and resolve any systemic issues, thus reducing the likelihood of costly corporate
crises and scandals. The implementation and adoption of effective and efficient governance systems that are geared to manage such eventualities may result in organizations being able to respond quickly to safeguard theirreputation;•
Improving top-level decision-making: Good governance can ensure timely access to information throughimproving the communication among stakeholders which may lead to better results. Moreover, good governancecan also foster rapid and accurate prioritizing of actions, which can be of invaluable importance especially inmoments of difficulties while contributing to the organization’s sustainability;•
Minimizes waste, risks, corruption and mismanagement: Organizations that are strongly committed to
implementing, adopting and maintaining good governance practices will likely find that certain risks are drastically minimized. The main reasons for this are that solid governance practices typically increase levels of transparency, trust and integrity, all of which solidly contribute to creating an environment conducive to reducing risks,
opportunities for corruption and any source of mismanagement;•
Diverse and balanced composition of boards and top management: Numerous studies have demonstrated that a more gender equal top management boosts the financial performance of a company along with higher
levels of transparency and stronger governance structures.
The following chart is the representation of the governance level of various countries where the composition of thechart is 50% based on executive capacity and 50% based on executive accountability.
* Notes - The edition of the SGI 2019 saw some modest changes in the composition of individual criteria of thecategories “executive capacity” and “executive accountability” compared to the editions of SGI 2014-18.

¹⁶ Basel Institute on Governance, Compliance without Borders a new way to build anti-corruption capacity in
SOEs, 2018
¹⁷ “OECD, The Guidelines on Corporate Governance of State-Owned Enterprises, 2015; OECD, The Guidelines on
Anti-Corruption and Integrity in State-Owned Enterprises, 201932

B20 POLICY PAPER INTEGRITY & COMPLIANCE

Policy Action 2.2: Assess ESG performances
Good governance is fundamental to successful ESG performance and to
the development of corporate cultures of integrity. Promoting a cultureof sustainability and positive impact among stakeholders through the acknowledgement and agreement of internally adopted compliance measuresrelated to sustainability issues is crucial. It is also important to promote theadoption of non-financial reporting, helping stakeholders and shareholders
to better evaluate the non-financial performance of businesses, while encouraging these companies to develop a more responsible approach to business, contributing to the assessment and mitigation of ESG issues which can
carry significant reputational and operational risks. To this end, standardized
non-financial reporting is key. Investments in ESG should be made across geographies, including less developed countries which may considerably contribute to better economic development. As a result of irregular practices
being normalized in different areas, it is necessary to promote a culture of
integrity and sustainability. Alongside the assessment of ESG, commitment isof equal importance to continue to place specific emphasis on gender equality, diversity and inclusion. To this end, the implications of inaction on genderequality, diversity and inclusion policies are tremendous as effective actions
may have a positive effect in preventing and countering corruption¹⁸¹⁸ UNODC, The Time is Now – Addressing the Gender Dimensions of Corruption, 202033

B20 POLICY PAPER INTEGRITY & COMPLIANCE

Focus - Measuring Sustainable Value Creation
Common Metrics and Consistent Reporting of Sustainable Value Creation
Without effective governance, we may fall short on the delivery of broader sustainability
goals. It is vital to strengthen good governance in ESG reporting. To contribute to achieving the SDGs and promote the harmonisation and standardisation of non-financial reporting, the World Economic Forum in collaboration with EY, Deloitte, KPMG and PwC
released a set of universal ESG metrics as a guidance for business reporting.
These 21-core metrics and 34 expanded metrics are organized across four pillars - governance, planet, people and prosperity - and serve as a roadmap for aligning businessperformance with stakeholder interests. As of January 2021, over 60 top business leadersacross industries have committed to the Stakeholder Capitalism Metrics.
Under governance, anti-corruption represents one of the core metrics for reporting
sustainable value creation. These metrics will be a key to achieving the SDGs. Investing
more efforts on the “G” piece helps build a solid integrity culture which is one of the related measures of fighting corruption.
Source: World Economic Forum, Measuring Stakeholder Capitalism Towards Common Metrics and Consistent
Reporting of Sustainable Value Creation, September 2020.

Policy Action 2.3: Improve integrity and compliance in supply chains
It is important to promote and foster the contribution to sustainable development, stimulating capacity building among SMEs and their supply chainsby offering training and guidance on RBC. Roles, responsibilities and accountabilities need to be defined and executed accordingly. In this sense, it remains crucial to properly understand and design measures which are also
adaptable by SMEs capacities, also by supporting existing networks that address SMEs’ specific needs¹⁹. To this end, it is also relevant to consider potential limitations and impact that SMEs may have in leveraging and influencing
the conduct of their respective suppliers. Companies of all sizes must invest
in the voluntary development of their supply chains for a step-change in sustainability impact, involving the utilization of purchasing power to encourage, audit, collaborate with, provide benchmarking and learning opportunities
with their suppliers on key sustainability issues, such as the promotion of solutions of circular economy. Another fundamental concept revolves aroundthe Human Rights’ topic, for which the Basel Institute is proposing to conveneand facilitate private sector roundtables, aiming to ascertain how companies
are currently conducting human rights and corruption risk assessments, andwhether they are already collaborating and combining their approaches. The
Basel Institute methodology could be used to support companies in a rangeof benchmarking exercises that respect confidentiality and proprietary information. Such a methodology could also contribute to providing a framework
to share experiences and to discuss opportunities, risks and methodologies
relating to human rights and anticorruption risk assessment, directly engaging with companies while also working with specialized organizations that
address human rights and business issues²⁰. In this regard, additional supporting guides, which connects the anti-corruption and human rights agendas are given. The guide aims at assessing the links as well as the differences
between the two issues while also providing pragmatic ideas for how companies can leverage existing synergies, implement a more coordinated approach
to risk assessments and foster experience and information sharing between
those working on anti-corruption and those working on human rights²¹. Furthermore, it remains fundamental to support capacity building of non-OECD
countries with poor governance and law enforcement through inter-governmental negotiations contributing to levelling the playing field for companies.
¹⁹ Alliance for Integrity – last update June 2021
²⁰ Basel Institute on Governance, Synergies in Anti-Corruption & Human Rights Compliance, 7 September 202034

B20 POLICY PAPER INTEGRITY & COMPLIANCE

Focus - Build resiliency into supply chain
Responsible and resilient supply chain
Today it is more important than ever to identify and understand risks and opportunities
in order to gain efficiency.
The OECD Guidelines for MNEs acknowledge and encourage the positive contributions
that business can make to economic, environmental and social progress, but also recognize that business activities may result in adverse impacts related to corporate governance, workers, human rights, environment, bribery, and consumers.
It is possible to reduce supply chain disruptions caused by social and environmental risks
through agreements with suppliers to explore how to best work together during the pandemic. Having a broad supply chain with a strong assurance that workforces are being
kept safe is a key factor of resiliency, above all for companies that source services fromall over the world. The investors positively consider companies that make smart decisions
regarding their supply chains during this crisis.
There are a number of studies that explore how companies are embedding sustainability
in their supply chains by managing risks and adopting new commitments around humanrights (such as the UN Guiding Principles on Business and Human Rights), the environment and the well-being of the communities in which they operate.
Results indicate that by improving ESG performance throughout the supply chain, companies can enhance processes, reduce costs, increase productivity, innovate, differentiate
and improve societal outcomes.
Eight ways to boost sustainability in supply chain are identified:
1.
2.
3.
4.
5.
6.
7.
8.

Assess materiality to focus on the most pressing issues, taking UN Global
Compact principles into consideration, which cover labour, human rights,
environment and anti-corruption;
Align resources, structures and processes to focus on supply chain
sustainability across the organization;
Train management and suppliers on market practices;
Invest in diverse and inclusive supply chain partners;
Stretch existing sustainability goals beyond direct operations, to include tiersof the supply chain;
Deploy technology to increase accountability and transparency;
Leverage buying power and influence to trigger shifts toward supply chain
sustainability;
Disclose supply chain information beyond stand-alone sustainability reporting
mechanisms.

Moreover, an intention of potential enhancement of the concept of sustainability within
supply chains is being represented among the latest EU consultations that might leadto a directive proposal. To this end, new obligations for companies could be envisaged:
carrying out proper third parties due diligences that contains all aspects that companies
should take into account before starting a new relationship, such as criminal record, reputational background, human labour conditions safety and security at work.

²¹ Business at OECD (BIAC), International Organization of Employers (IOE), Connecting the anti-corruption andhuman rights agendas: A guide for business and employers’ organisations, September 202035

B20 POLICY PAPER INTEGRITY & COMPLIANCE

Recommendation 3: Cooperative compliancemodels and rewarding systems
Integrity and compliance should become milestones for organizations through the promotion and rewards of specific voluntary management commitments. To this end, it is worth mentioning that companies are making great
progress in implementing and improving their compliance programs. In thiscontext, it is relevant to focus on better understanding and managing associated risk profiles by implementing and adopting effective compliance programs as well as due diligence policies and third-party risk management. Indeed, it is fundamental to strengthen companies internal control frameworks
when it comes to managing relationships with third parties alongside thesupply chain in order to gather reliable information on the related beneficial
owner, thus avoiding committing illicit action and crimes in the procurement
cycle. Oversight of internal controls and compliance programs should be theduty of one or more senior corporate officers, endowed with an adequatelevel of autonomy, resources and independence from management²². There is also a strong need to foster dialogue, enhance cooperation, trust andstrategic alignment among public and private organizations, to build a global
culture of sensibility towards compliance and integrity, maturating intolerance towards corruption²³. In this context, cooperative compliance models
should be promoted with governments providing incentives/rewarding forthe adoption of compliance programs²⁴.
Governments should strive to harmonize compliance requirements acrossjurisdictions to reduce the costs and complexity that companies incur to create a level playing field for global business and to facilitate the enforcementof compliance across jurisdictions. In addition, supportive measure with regards to the implementation of efficient whistle-blower reporting and protection systems by innovative communications technology is key. Collective
Action activities play a crucial role in providing solutions to emerging andevolving risks. These activities are collaborative and sustained multi-stakeholder efforts that are integral to the creation of integrity cultures that go
beyond compliance²⁵. In particular, they can be effective in the implementation of policies that address market integrity, supply chain due diligence,and third-party risks in the creation of standardized non-financial reporting
standards that emphasize the importance of effective governance in creating sustainable growth.

²² G20, High-level Principles on the Private Sector, 2015.
²³ G20, High-Level Principles for the Effective Protection of Whistle-blowers, 2019²⁴ UNODC, Resource Guide on State Measures for Strengthening Corporate Integrity, 2013
²⁵ WEF, Collective Actions. An Agenda for Business Integrity – four key pillars of leadership action
by companies, 202036

B20 POLICY PAPER INTEGRITY & COMPLIANCE

Policy Actions
3.1 Promote public-private cooperation to enhance compliance – Reinforcing the concept of reward by fostering collective trust in cooperativecompliance efforts, promoting the adoption of rules, effective measuresand inclusive cooperation to improve the exchange and availability of information among stakeholders from the private-public worlds, aiming
at increasing compliance and good conduct.
• The G20 should foster the adoption of rules, effective measures andinclusive cooperation to improve the exchange of information between the public and private sector. Further, they should look to promotereward policies linked to compliance efforts.
• The G20 should encourage, in collaboration with the governments,
the implementation and adoption of robust compliance programs forcorporations who access public tenders and receive public funds.
• The G20 should encourage the development and adoption of an effective rewarding system, fostering voluntary cooperative complianceefforts with dedicated authorities.
• The G20 should promote Collective Action activities and public-private partnerships to enhance the exchange of best practice and the development of information sharing methods.
• The G20 should encourage governments to adopt supportive legal
and guidance frameworks to promote Collective Action activities, defining a sustainable process of collaboration and cooperation among stakeholders from the private and public sector, with the aim of increasing
the scale and effectiveness of anti-corruption actions.
• The G20 should stimulate the adoption and implementation ofeffective measures, such as ICC anti-corruption clauses (especially inpublic procurement contracts), and Integrity Pacts in key contracting
projects, in order to increase transparency and accountability, enhance trust in authorities and government contracting, and contribute to agood reputation of contracting parties.
3.2 Corporate compliance efforts in private sector – Implementing due
diligence policies by hiring companies within the supply chains for theselection and review of contractors, better manages associated risk
profiles while supporting SMEs in the due diligence of their commercial partners (e.g. supporting the adoption of a long term, aspirational
concept such as Global Value Chain Passport for financial compliance). In this context, governments should consider providing incentives
for companies to adopt compliance programs, promoting the adoption
and implementation of digital solutions. Such initiatives will need to befollowed by the implementation of subsequent rewarding mechanisms
for entities excelling in the adoption of the above (e.g. update of publictenders score cards for virtuous entities).
Governments should also request companies, especially large enterprises, to provide training to their suppliers, so that a culture of businessethics is strengthened not only within the company but also along their
supply chain, creating value and positive externalities with regard to ESG
factors.
37

B20 POLICY PAPER INTEGRITY & COMPLIANCE• The G20 should stimulate business to implement and adopt integrity principles and compliance cultures within organizations, while governments take into consideration compliance efforts and voluntary self-disclosure by businesses through rewarding mechanisms. These efforts
should be promoted with a strong focus on implementing digital solutions.
• The G20 should promote self-disclosure by offering reduced penalties and leniency programs, ensuring the re-inclusion of firms which havecome clear in public tenders.
• The G20 should encourage companies to conduct properly documented risk-based due diligence on commercial partners to manage
associated risk profiles, while at the same time reinforcing responsible
business conduct and fostering compliance with relevant legislation.
3.3 Protection of whistle-blowers – Improving compliance for the private
and public sector, reinforcing and rebuilding trust in public and private institutions through the adoption of effective and efficient whistle-blower
reporting and protection systems supported by innovative communications technology is crucial. In this context, it is key to focus both, on therights of the person against whom a report has been made, the protection of the reporting person as well as the freedom from retaliation.
• The G20 should encourage the adoption and implementation ofeffective and efficient whistle-blower reporting and protection systems, as well as fostering dedicated communication activities aiming toenhancing awareness, while reinforcing workers’ and stakeholders’ trust.
• The G20 should encourage the reinforcement of protecting the reporting person as well as requiring that there is no retaliation against
individuals who raise concerns in good faith.
• The G20 should foster a robust exchange of information through theuse of modern digital tools between government and business in orderto monitor and evaluate their whistle-blower protection frameworks,
and to lay down and update international high-level standards.
• The G20 should implement dedicated reporting systems for public
officials to directly address issues to the highest level of the respective
administration through innovative whistle-blower communications technology and create high-level reporting mechanisms through supervising authorities.
Key Performance Indicator
The B20 Integrity & Compliance Taskforce proposes that current and future G20 presidencies monitor progress on the Countries with National Laws
Protecting Whistle-blowers. The proposed KPI, as inserted below, shows therelative ownership, the given baseline and the 2024 target ambition.

Countries with National Laws
Protecting Whistle-blowers

Owner: Environmental
Law InstituteBaseline
32(2017)For further details please see the relative Annex.
38

Target54(2024)

B20 POLICY PAPER INTEGRITY & COMPLIANCE

SDG impacted - 1: No Poverty - Public private cooperation may improvethe business environment and increase competitive opportunities for private
investment, strengthening poverty alleviation and focusing the government's
economic management. 5: Gender Equality - Through the promotion of
specific voluntary management commitments there may be examples of abetter involvement of gender distribution. 8: Decent Work and Economic
Growth - Introducing and leveraging collaborative measures or rewarding
systems for ethical and anti-corruption measures adopted voluntarily cancontribute to sustainable economic growth. 9: Industry, Innovation andInfrastructure - Utilizing innovative technologies to enhance whistle-blower
communication and protection creates a better and more secure ecosystem.
10: Reduced Inequalities - Rewarding compliance and ethics efforts of private companies as leverage to stimulate good conduct, empowerment andsocial, economic and political inclusion fostering the reduction of inequalities. 16: Peace, Justice and Strong Institutions - Enhancing efficiency andcooperation among public and private sector to identify and minimize potential risks (legal, social, reputational) in business conduct, fostering peaceful and inclusive community and effective governance. 17: Partnerships
for the Goals - Encouraging private and public global cooperation that goesbeyond official development assistance commitments.
Italy's G20 principles - People: Enhance and reinforce employees protection measures while increasing efficiency through Collective Action activities aimed at improving individual’s wellbeing and collective trust. Planet:
Promoting cooperative compliance efforts and rewarding systems can havea substantial impact on the implementation and adoption of a global cultureof sustainable integrity. Promoting specific voluntary management commitments will positively affect environmental behaviour. Prosperity: A cooperative approach to implementing and adopting an effective reward system willstrongly contribute to the enhancement of compliance levels among organizations, raising the bar of transparency, efficiency, and responsible businessconduct among organizations.
Context
Corporate compliance, strong corporate culture and business ethics are prerequisites for the sustainability of each company. Concurrently, organizations
are navigating new compliance challenges emerging as a result of COVID-19.
Therefore, especially in this moment of unprecedented challenge, there isan essential means to build a sustainable culture of integrity and inclusiveness aiming at better responding to the raise of pandemic challenges. In thiscontext, the external ecosystem plays a key role in organizations promoting
and stimulating a global culture of sustainable integrity through specificvoluntary management commitments. There is a need to work closely andcohesively towards building a better and stronger win-win solution whereorganizations increasingly commit to good and responsible conduct while
governments and institutions facilitate, remunerate and cooperate towards
the sustainability of this cycle.
Moreover, encouraging corporate compliance efforts contribute to fulfil andsupport the 2030 Agenda for Sustainable Development and especially SDG
16, which deals with “Peace, Justice and Strong Institutions,” and also targets
16.5 of this goal, which is “Substantially reduce corruption and bribery in all
their forms.”
It is important that Governments act, providing incentives for business toestablish compliance programs by taking into consideration the existence39

B20 POLICY PAPER INTEGRITY & COMPLIANCE

of such programs when awarding public contracts, recognizing effectivenessand performance.
Another way to support corporate compliance efforts is to encourage self-disclosure and self-cleaning by offering reduced penalties and leniency
programs, allowing the re-inclusion of firms which have come clear in publictenders.
Policy Action 3.1: Promote public-private cooperation to enhance complianceReinforcing the concept of rewarding to foster collective trust in cooperative compliance efforts with dedicated authorities as well as ensuring corporations will be equipped with effective and robust compliance programs iskey, especially when accessing to public tenders and receiving public funds.
In such context, it might be of great value allowing the contamination of public systems by virtue of sustainable processes implemented by the private
sector, as well as leveraging the innovation developed by the private sector in
the sustainability field to foster higher compliance and efficiency standards.
These measures can have great impact on incentivizing and encouraging
compliance while also contributing to levelling the playing field for businesses. In this context, sufficient flexibility in the design of bidding criteria must
be in place, as well as avoiding extensive check lists which risk burdening andultimately, potentially penalizing SMEs from public tenders.
Collective Action activities between public-private sectors should also beconceived as a means to convene power among diverse actors to align/heighten ethical standards and curtail corruption. In this context, private andpublic sector should work together to address their legislative and regulatory
approach and identify adequate solutions. These partnerships should leverage the gatekeeper’s expertise and technological know-how and promote
the fight against illicit financial flows. Other measures, such as tax cooperative compliance agreements, are broadly seen as an exchange of greater
upfront transparency by the taxpayer in return for more certainty from thetax authorities. Such measures also reduce compliance costs and enhance
efficiency, due to the better utilization of resources by both parties. Many
countries formalize cooperative compliance arrangements in some kind ofwritten agreement with taxpayers, such as a special ruling or dispensationfrom the tax authorities or a formal cooperative compliance agreement. Furthermore, implementing and promoting the adoption of rules, effective measures and inclusive cooperation is fundamental to improving the exchange
and availability of information, offering a type of collaborative and sustained
process of cooperation among stakeholders from the private, civil and publicworlds aiming at increasing compliance and good conduct.
Exhibit 6
Governance

TGI growth and issue areas - Transnational public-private governance initiatives (TGIs) are an important element of contemporary world politics, in which states and/or intergovernmental organizations (IGOs) cooperatewith business and civil society actors to govern transnational problems. They represent a special type of transnational public-private partnership (PPP). In contrast to traditional state-based regulation, in TGIs, private actors
are not only the objects of governing, but are involved in the core activities of governance process, including decision-making, monitoring, and enforcement.
The left-hand panel of the chart below represents the net cumulative total numbers of TGIs. The chart clearlyshows an initial slow growth rate of TGIs up until the 1980s while there is an exponential growth between 1990
and 2010, which keeps increasing up until today. While it is interesting to see that on the right-hand panel ofthe chart below, TGIs are frequently created to address social, development, and environmental problems. In thiscontext, the thematic areas of interest, mainly integrity and compliance can find enough space to play a key role
among TGIs initiatives.

40

B20 POLICY PAPER INTEGRITY & COMPLIANCE

Figure 8 - Westerwinter, O. Transnational public-private governance initiatives in world politics - 2019
The following chart reports on the two sides of the panel, state and IGO participations in TGIs that existed in 2017

Figure 9 - Westerwinter, O. Transnational public-private governance initiatives in world politics - 2019

Focus | Spotlight on Collective Action
Leveraging Collective Action to build alliance against corruption
Collective Action is a process that brings together civil society, government and businesses
to solve intricate and shared problems. Considering that corruption is a wide-spread phenomenon that must be tackled by the largest possible number of actors, Collective Action
is crucial in developing anticorruption initiatives within the private and public sector.
An example of Collective Action is the project Global Integrity Education implemented by the United Nations Office on Drugs and Crime (UNODC). The project seeks toestablish effective integrity education programmes that foster ethical decision-making
in private sector employees. To achieve this goal, UNODC has set up working groups
in Kenya, Mexico and Pakistan which bring together private sector representatives andacademics to develop contextualized university integrity modules. Practical examples
and guest lecturers from the private sector increase the relevance of the material taught
to students. The ultimate goal of the project is to create a talent supply chain of university graduates who are empowered to act as ethics ambassadors and seek to join public
or private sector organizations.
Source: Siemens Integrity initiative Annual Report, 2019.

41

B20 POLICY PAPER INTEGRITY & COMPLIANCE

Policy Action 3.2: Corporate compliance efforts in private sector
Implementing and adopting due diligence policies by the hiring company
and within the supply chain for the selection and review of contractors, tounderstand and manage associated risk profiles, thus reinforcing responsible business conduct and compliance with relevant legislation on e.g., labour, human rights, environment is crucial. Effective due diligence should be
supported by efforts to embed RBC into policies and management systems
aiming at enabling enterprises to remediate adverse impacts that they cause or to which they contribute²⁶. For the same reason, it would be crucial tosupport SMEs in the due diligence of their commercial partners. To this end,
it is also relevant to consider fostering the development of targeted guidance
to support SMEs in developing tailored compliance programs including also
consideration on themes such as: labour human rights and environment²⁷. In
this context, governments could provide incentives for companies to adopt
compliance programs, e.g., by considering them when awarding public contracts, and encourage self-disclosure by offering reduced penalties and leniency programs, ensuring the re-inclusion of firms which have come clear
in public tenders. Enterprises should be viewed as partners with government
in the development and use of both voluntary and regulatory approaches topolicies affecting them²⁸. In addition, a further and relevant element worth
consideration is the introduction of the Global Value Chain (GVC) Passport.
The above-mentioned tolls enable a company to operate across geographies
without the need to reproduce the same documentation on multiple occasions, nor undergoing duplicative verifications.
These efforts should also be promoted with a strong focus on implementing digital solutions, such as compliance process automation (e.g., controls
testing and monitoring, complaints analysis, etc.) through the adoption of
new technologies (e.g., artificial intelligence and blockchain). At present,
main progress in these areas has been made by large corporations, so further efforts should be made to make them accessible for smaller companies,
to ensure innovation and quality data sharing for all companies. To this end,
governments should support enterprise’s digital transformation by including
within incentive policies, the consideration of internal organizational measures regarding compliance processes.
Focus - Spotlight on GVC
Introduction of Global Value Chain (GVC) Passport
The Passport was the result of the joint cooperation between the Saudi Arabia B20 andBusiness at OECD (BIAC). The common intent is to make cross border trade easier for allcompanies, especially SMEs, which are currently held back by an excessive red tape. The introduction of the “GVC Passport”, incorporated in one participating country, would thereby be reciprocally acknowledged as a legitimate business entity in other participating
countries; henceforth, facilitating its financial capability across the GVC by recognizing
all those financial compliance and regulatory requirements already fulfilled.
The development of GVC Passport is an opportunity to maximize the use of existing data,
provide an authenticated, authoritative, verifiable financial fingerprint of a given entity,
enabling it to operate within GVCs in a cheaper and more efficient way.
Source: Business at OECD and Saudi B20 “GVC Passport” on financial compliance, apragmatic concept to strengthen Inclusive and Sustainable Growth, 2020.

²⁶ OECD, Due Diligence Guidance for Responsible Business Conduct, 2018
²⁷ Alliance for integrity – THEINTEGRITYAPP – last update June 2021
²⁸ OECD, Guidelines for Multinational Enterprises, 201142

B20 POLICY PAPER INTEGRITY & COMPLIANCE

The 2014 OECD Foreign Bribery Report found that three in four cases of foreign bribery involve some sort ofthird-party intermediary, such as an agent, consultant, distributor, broker, or even subsidiary.
According to the Survey represented in the document “Corporate Anti-Corruption Compliance Drivers, Mechanisms, And Ideas For Change”, the risk that a third party agent will engage in corrupt conduct that will be imputed
to the agent means that nearly all companies that have an anti-corruption compliance program engage in some
sort of oversight of the business partners with whom they work.

Exhibit 9
OECD reporting on third
party risk management and OECD
Guidelines on Responsible
Business Conduct

OECD Survey on Drivers and Models of Corporate Anti-Corruption Compliance
Figure 10 shows the types of activities respondents to the survey indicated that their companies undertook in orderto protect against bribery or corruption by a business partner.
It is possible to see that almost 80% of respondents conduct documented pre-contractual due diligence aboutanti-corruption programs.
Further, it is remarkable that more than 90% of companies surveyed include anti-corruption language in contracts with partners.
Finally, almost 60% of respondents has a confidential whistle-blower reporting mechanism in place.

Figure 10– OECD, Survey on Drivers and Models of Corporate Anti-Corruption Compliance, 2020

Policy Action 3.3: Protection of whistle-blowers
Improving compliance with legal rules²⁹, standards and procedures for private and public sector, reinforcing and rebuilding trust in public institutions
through the adoption of efficient whistle-blower reporting and protection
systems supported by innovative communications technology systems is
key³⁰. Modern technology widens the access of whistle-blower systems, considering by definition, individuals, which take part to a working environment,
thus contributing to enhancing transparency while also considering data protection and data privacy. As it is recalled in the G20 High-level Principles on
Whistleblowing, there is a substantial need to focus both on the rights of theperson against whom a report has been made, the protection of the reporting
person as well as freedom from retaliation. To this end, the protection of awhistle-blower’s identity along with the prohibition of all forms of retaliation
protection against legal proceedings and sanctions for retaliation or interference are essential elements of an effective protection framework is key. It
will be also key to contribute to the awareness of whistleblowing mechanisms
through the implementation and adoption of effective communication campaigns aiming at informing and disseminating legal rights of whistle-blowers
and dedicated activities that support the development of an internal cultureof trust and transparency in private and public entities.
In this context, it is of same importance to create and promote internal channels that are granted with the necessary independence for receiving assessing investigating and acting on reports and foster an organisational culturethat builds confidence in reporting³¹.
²⁹ DIRECTIVE (EU) 2019/1937 of 23 October 2019 on the protection of persons who report breaches of Union law³⁰ UNODC, resource guide on good practices in the protection of reporting persons - details existing international
requirements and provides guidance on the implementation of protection systems, 201543

B20 POLICY PAPER INTEGRITY & COMPLIANCE

Exhibit 6
Governance

Reporting amongst workers is still rare - Whistle-blowers can act as an early warning to prevent damage anddetect wrong doings in public and private organizations. However, for many reasons, whistle-blowers are often
discouraged from reporting their concerns for fear of retaliation.
•
Most respondents (85%) believed that workers very rarely or rarely report concerns about threat or harm to
the public interest.
•
Individuals were more likely to state that workers very rarely reported their concerns (46% against 29%).

Figure 11 – European Commission, Summary results of the public consultation on whistle-blower protection ICF
from OPC data, [Base N: individuals=5,484 organizations N=180] [Q: To your mind, how often are workers reporting their concerns about threats or harm to the public interest, 2017
Awareness of whistle-blowers protection - Protection of Whistle-blowers is fragmented across the EU, but it hasa unique and relevant role to play in the actual scenario. Although efforts have been made on adopting measureson whistle-blower protection, the level of awareness remains underdeveloped, demonstrated by the several negative events that occurred, highlighting how insufficient the protection is. Thus, the negative impact is reflected on
the functioning of EU policies and therefore could also spill over in other countries.

Figure 12 - European Commission - Whistle-blower protection Fact sheet | April 2018³¹ In recognition of the importance of whistle-blower reporting systems for building integrity in the private andpublic sector ICC has launched a revision of its ICC Whistleblowing Guidelines by a Working Group of 50 company
executives from over 20 countries.

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Recommendation
Transparency

4:

Beneficial

ownership

To fight anonymous shell companies that contribute to enabling corruption,
fraud, organized crime and tax evasion, it is key to transform beneficial ownership transparency into an inescapable legal requirement. Anonymouscompanies undermine trust, distort competition, discourage investments
and deprive countries from revenues, making it more difficult for developing
countries to achieve the SDGs. To this end, a step forward has been madewith the introduction of the Corporate Transparency Act (the CTA), enacted
by the US congress on 1 January 2021. Such an initiative will mainly require
corporations, limited liability companies and other similar entities to disclose beneficial ownership information to the Financial Crimes Enforcement
Network (FinCEN). Moreover, the G20 Anti-Corruption Working Group
Action Plan 2019-2021³² has put the topic at the centre of the agenda, highlighting that transparency of beneficial ownership is critical to preventing
corruption and the laundering of corrupt proceeds, as well as to maintain integrity and trust in tax administration systems. In line with the G20 High-Level Principles on Beneficial Ownership Transparency³³ and with international
standards such as those set by the Financial Action Task Force (FATF)³⁴, key
points for the compliance assessment on beneficial ownership transparency
should include: a uniform definition of “beneficial owner”, to consider thenotion of ultimate (actual) ownership and control; mechanisms to ensure
adequate sharing of beneficial ownership information; accurate and up-todate information on beneficial ownership and accessibility of this information by competent authorities in a timely manner. In a world where digitaltransactions are increasingly growing³⁵, opening further space for criminal
infiltration, to establish digital identity standards – including identiﬁers which may be used by decentralized systems – for individuals and businesses tohelp verify beneﬁcial ownership data is a critical step to enhance security. In
this sense, leveraging the use of innovative technology to enhance access tohigh-quality data on who owns companies is essential to prevent and tackle
corruption, financial and organized crime. Countries should adopt legislationand supportive elements, e.g., analytical and investigative instruments, thatallow the prompt identification of effective beneficial owners of the wealthaccumulated by (and reinvested in) crime, creating a level playing field for allcompanies while ensuring the necessary control mechanisms are in place tomitigate potential risks. In addition, gatekeepers, as professionals performing
several important functions in helping their clients organize and manage
their financial affairs, play a fundamental role to help addressing the non-disclosure of beneficial ownership information. Therefore, it is important for
the G20 members to promote global framework and develop legislation on
digital identities and beneficial ownership transparency to standardize thecreation, collection, validation, monitoring and maintenance of beneficial
ownership information by governments. As the level of cooperation and information sharing on beneficial ownership at the international levels is essential, G20 members are also committed to support other countries to implement beneficial ownership standards.

³² G20, Anti-Corruption Working Group Action Plan 2019-2021, December 2018³³ G20, High Level Principles on Beneficial Ownership Transparency, 2014
³⁴ FATF, Guidance Transparency and beneficial ownership, October 2014
³⁵ “Digital payments are growing at an estimated 12.7% annually and are forecast to reach
726 billion transactions annually by 2020. By 2022, an estimated 60% of world GDP will be digitalized”:
FATF, Guidance on Digital Identity, 202045

B20 POLICY PAPER INTEGRITY & COMPLIANCE

Moreover, together with traditional high-risks sectors, transparency should
be enhanced in financial activities that take place among non-bank financial Intermediation (NBFI) which includes insurance firms, venture capitalists,
currency exchanges, some microloan organizations, and pawn shops. Assuring that the necessary information on these transactions – in particular, on
the borrowers/beneficial owners – is reported through appropriate repositories may contribute to tackling major opacity risks. Furthermore, there areareas of business that require specific attention being exposed to such risk.
Among the most affected ones, the sport industry requires a strong need for
integrity and transparency in relation to the ownership of sports organizations, encompassing the respective financial transactions, vehicles and jurisdictions, as well as all involved individuals and organizations.
Policy Actions
4.1 Adopt technology to ease access to Beneficial Ownership information – Fostering the adoption of innovative digital technologies, such as
Artificial Intelligence, machine learning and Blockchain, and allowing toaccess and share reliable information reliable information on beneficial
ownership is key.
• The G20 should stimulate the digital identity standards requiring
bidders to disclose beneficial ownership information in the procurement cycle, supporting the implementation of Financial Action Task
Force (FATF) recommendations and guidance on digital identities andbeneficial ownership to standardize the creation, collection, validation,
monitoring and maintenance of beneficial ownership information by
governments.
• The G20 should encourage the adoption of innovative digital technologies to collect, store and analyse data and to allow access and sharing of relevant and reliable information on beneficial ownership – including information on borrowers in Non-Bank Financial Intermediation(NBFI) – utilizing adequate measures and inclusive cooperation to improve the exchange and availability of information.
• The G20 should foster the improvement of data quality including
data security and data updates including through the adoption of the
global best practice Beneficial Ownership Data Standard (BODS), raising global standards through modern supportive technology, monitoring the implementation and reporting on progress through effective,user-friendly and transparent reporting systems.
4.2 Develop digital public national registers – Increasing transparency
around beneﬁcial ownership information, improving third-party risk
management while ensuring the data stored in digital national public
registers is accurate and up to date is essential. It is important to implement measures by the government to facilitate public access to this typeof information – since on many occasions people are not even aware of
the availability of the same – which may contribute to good governance.
• The G20 should foster the development of comprehensive andwell-resourced digital public beneficial ownership national registers, while considering the implementation of proper corporate registries, aimed
at increasing transparency around beneﬁcial ownership information andto improve third-party risk management, ensuring that the data stored
in digital national public registers is both accurate and up-to-date.
46

B20 POLICY PAPER INTEGRITY & COMPLIANCE• The G20 should promote, through the use of innovative technology, an effective campaign of data quality sharing, through an effective
public-private partnership project engaging relevant stakeholders toassess the technology landscape and develop standards to improve data
quality in, and data sharing among, national registers.
• The G20 should encourage gatekeepers to proactively establish asystem for evaluating and addressing entities that do not disclose beneficial ownership information reporting discrepancies with data in public
registers as well as suspicious activities to competent authorities.
• The G20 should accelerate its efforts to establish digital public national registers, requiring legal entities to raise the bar of their level oftransparency and accountability in all governments services and activities posing attention on public procurement, in such a way that they alignalso with the minimum standards of transparency promoted by the G20.
• The G20 should support developing countries with the creation,
development and maintenance of reliable company registers by promoting beneficial ownership transparency with technical and financial
assistance, expanding access and exchange of relevant information with
non-G20 countries, especially with regard to the information held anduse made of public registers.
4.3 Enhance power and independence of authorities – It is crucial to constantly promote the sharing of up-to-date information, regarding legal
arrangements, discouraging bearer shares or, at least, adopting measures that allow for the identification of the beneficiary of the shares. Nominees should be required to disclose their status and subject to strict
anti-money laundering obligation as well as regulating nominee shareholders or directors while fostering companies’ support into creating
fairness through a set of common rules and standards designed to level
the playing field.
• The G20 should foster a culture of cooperation through the implementation of an effective system to reinforce international cooperation
among international organizations and authorities, while committing tocontribute in the creation and consolidation of fairness through a set ofcommon rules and standards levelling the playing field, and by the identification of members and non-member states that require financial or
technical assistance in developing digital public national registers.
• The G20 should encourage organizations to adopt and implement
digital records, giving access upon request to relevant authorities, whichshould be kept for a certain period of time, promoting a culture of voluntary self-disclosure.
• The G20 should promote joint work with the governments of eachcountry in the implementation of a facilitated system for competent authorities’ access to trust, or similar legal arrangements, by setting up asystem for the central registration of trusts, requiring to record information such as the registrar on the trust’s settlors, trustees, beneficiaries,
trust deed and/or assets.
• The G20 should foster the development of an effective and reliable
integrated system, covering all the vehicles that might be used by criminals to conceal their ownership and control of such vehicles, giving publicaccess to information to all relevant domestic competent authorities.
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Key Performance Indicator
The B20 Integrity & Compliance Taskforce proposes that current and future
G20 presidencies monitor progress on the Worldwide commitments andaction - countries are fully committed to Beneficial Ownership Transparency. The proposed KPI, as inserted below, shows the relative ownership,
the given baseline and the 2024 target ambition.

Worldwide commitments
and action - countries are fully committed
to Beneficial Ownership Transparency

Owner: OpenOwnership
Baseline48(2020)

Target83(2024)For further details please see the relative Annex.
SDG impacted - 9: Industry, Innovation and Infrastructure - Increasingtransparency in beneficial ownership through investment in innovative andsustainable technology infrastructure can help increase economic growth.
16: Peace, Justice and Strong Institutions - Increasing transparency in thiscontext would increase trust in organisations by stimulating a more inclusive
community. 17: Partnerships for the Goals - Actions to increase transparency in beneficial ownership can solidly contribute to sustainable development by stimulating international cooperation, collaboration and by assistingdeveloping countries to mobilise domestic resources.
Italy's G20 principles - People: Increasing transparency with regards tobeneﬁcial ownership information may strongly contribute to increasing public awareness about transparency issues while simultaneously increasing
employee demand for corporate responsibility contributing to enhancing
people trust. Prosperity: Promoting the enhancement of beneficial ownership transparency levels may strongly contribute to level the playing field forbusinesses, while offering better business intelligence practices and support
for SMEs.
Context
The United Nations Office on Drugs and Crime (UNODC) estimates between
US$800 billion and US$2 trillion of laundered money³⁶, much of which passes
through anonymous companies. The achievement of the Agenda 2030 for
Sustainable Development is at risk if governments do not act against tax evasion and corruption and recover stolen assets. The transnational nature offinancial crime demands a coordinated solution. Moreover, unmasking andinvestigating the individuals behind anonymous companies often requires
international cooperation between governments, law enforcement agents,
journalists and civil society organizations. Indeed, although many countries
have adopted regulations establishing national registers of beneficial ownership information and recently an important step forward has been taken
at the European Union level – through the establishment, following the 5th
Anti-Money Laundering Directive, of a system of interconnection of central
registers of Member States – much remains to be done, as a significant number of G20 countries do not have these registries³⁷.

³⁶ UNODC, Annual Report, 201848

B20 POLICY PAPER INTEGRITY & COMPLIANCE

In fact, beneficial ownership transparency may play a key role in the fightagainst corruption. Article 12 of the UNCAC requires that States Parties
take measures to promote transparency among private entities, including
measures regarding the identity of legal and natural persons involved in theestablishment and management of corporate entities. The construction ofcomplex structures, such as anonymous shell companies and trusts as provided for by the legislation, might give criminals the possibility to hide theirassets, as well as to cover them up for the purposes of entering them into
the financial system, potentially contributing to enabling corruption, fraud,organized crime and tax evasion. Therefore, there is a concrete need to takeaction to implement pragmatic solutions which may combat this phenomenon. The adoption of legislation and use of investigative instruments that allow the identification of effective beneficial owners, on the one hand, and theimplementation of innovative and effective technologies enabling access tohigh quality data, on the other, is essential to tackle corruption and financial
crime, including money laundering, and to recover stolen assets.
Governments and businesses are strongly interested in fostering beneficial
ownership transparency and collecting reliable information about company
owners, therefore contributing to competitiveness and risk reduction. Indeed, transparency enhancement provides an overall better understandingof the business environment and related counterparts. In this context, eventhough it is proven that the existence of critical themes such as money laundering and tax evasion negatively affect and impact the majority of industries, a greater attention must be place on vulnerable industries. To this end,
the sports industry lack of transparency, renders it essential to focus on fighting opaque ownership structures while enhancing beneficial ownershiptransparency in its entities.
Policies on beneficial ownership transparency should be developed and implemented in an international, multi-stakeholder way. Transparency is a key
condition for the success of a central register of beneficial ownership information. Establishing public register is good practice because it ensures thatdomestic, foreign and international law enforcement agencies and tax authorities have free and immediate access to data.
Nevertheless, it should be taken into account that the exchange of beneficial
ownership data can raise complex cybersecurity, risk management and privacy issues. In this respect, once again technology – such as blockchain andartificial intelligence, but also privacy enhancing techniques – may contribute to find solutions to strike the right balance between privacy concerns,
transparency and the fight against illicit financial flows³⁸.

³⁷ On March 1st, 2021, the European Commission enacted the Implementing Regulation 2021/369 establishing
the technical specifications and procedures required by the EU Directive 2015/849 for the set-up of the Beneficial
Ownership Registers Interconnection System (BORIS)³⁸ World Economic Forum, The Next Generation of Data-Sharing in Financial Services: Using Privacy Enhancing
Techniques to Unlock New Value, September 201949

B20 POLICY PAPER INTEGRITY & COMPLIANCE

Exhibit 11
Worldwide commitments

Commitments to beneficial ownership transparency - The following chart and data aim to illustrate and represent worldwide commitments and actions undertaken by countries with regards to beneficial ownership transparency, where measures such as open registers are in operation.

Figure 13 – Open Ownership – last update August 2020

Figure 14 - Open Ownership – last update August 2020

Focus - Spotlight on GVC
The benefit of beneficial ownership in the public procurement
Beneficial Ownership transparency and efficient use of data in procurement represents apivotal tool to detect illegal practices and oversight, and verification and accountability
by civil society and the public through the publication of data.
The illustration reported below clearly shows that the interaction across data source,
data collection and use cases allows a transparent publication of data and reliable internal analysis. Therefore, the procurement practices could be enhanced in terms of integrity, efficiency and effectiveness.

50

B20 POLICY PAPER INTEGRITY & COMPLIANCE

Figure 15 – Open ownership, Beneficial Ownership data in procurement (Adapted from
mySociety and SpendNetwork), March 2021
The central register is crucial to allow Governments to collect Beneficial Ownership (BO)
information for all business actors. Economy-wide registers and commercially available
BO data are easily accessible data sources critical to enhancing transparency practices inpublic procurement and reduce risk within their own due diligence processes.
The Beneficial Ownership data use cases can be used for improving procurement activities such as preventing corruption and fraud, improving service delivery, and verifying
eligibility of suppliers for preferential procurement.
Source: Open Ownership, Beneficial Ownership data in procurement, March 2021.

Policy Action 4.1: Adopt technology to ease access to Beneficial Ownership information
Fostering the adoption of innovative digital technologies (e.g. blockchain)allows access to share relevant and reliable information on beneficial ownership, enhancing public accountability and trust across companies. In thiscontext, Governments should ensure that they have legislations in place toenact the FATF standards on beneficial ownership and that an effective cooperation between FIUs, tax and customs administration, justice departments, central banks and other law enforcement agencies to counter all pointsof financial and tax crimes. A considerable framework, aiming at easing data
accessibility, is represented by Beneficial Ownership Data Standard (BODS)
which provides a structured template for describing beneficial ownership as
machine-readable data. The BODS enables transparency by providing a solid
conceptual and practical framework for collecting and publishing beneficial
ownership data, resulting in data that is interoperable, more easily reused,
and of higher quality³⁹.

³⁹ Open Ownership, last update April 2021

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B20 POLICY PAPER INTEGRITY & COMPLIANCE

Policy Action 4.2: Develop digital public national registers
Increasing transparency around beneﬁcial ownership information, improving
third-party risk management, and ensuring that the data stored in digital national public registers is both accurate and up to date is critical. The implementation of platforms that link up national public registries and the promotion ofinter-agency cooperation between the different law enforcement agencies
engaged in the identification of beneficial ownership of opaque vehicles are
key in the establishment of adequate transparency on beneficial ownership.
There is an incremental need to introduce digital national public registers inpublic procurement as citizens are keen to know who governments are really
doing business with, rendering it essential to know the legal ownership of acompany, as well as who the ultimate beneficial owner benefiting from andexercising control over a company is. In such context, the potential establishment of dedicated systems and tools aimed at easing the evaluation of entities that do not disclose beneficial ownership information could be extremely
relevant. Due to the fact that, non-transparency in such matter might lead tointer alia, malpractices and illicit activities, it is crucial to create a solid collaboration with gatekeepers, (e.g., company formation agents, lawyers, professional services firms, accountants, and trust-and-company-service providers)
in designing and implementing the above-mentioned system. In this context,
a relevant prerequisite worth considering is the promotion and adoption by
G20 member States of a standard set of rules which encompass proceduresfor the formation and maintenance of a national beneficial ownership register.
The formation of a national beneficial ownership register should be based on
the principle of a balance of transparency and protection of personal data ofbeneficiaries.
In addition, in order to avoid criminal infiltration, Governments could also
implement a control system on the competent Chambers of Commerce sothat to ensure that changes in ownership structures and therefore beneficial
ownership transparency are subject to formal pre-notification information
to be made public to whoever has access to the registry. This could rise thelevel of attention and awareness and permit in-depth checks due diligenceson the new potential partners and would make it possible to intercept any
alarm signals and maybe with regard to the competent Authorities interrupt
transactions carried out with malicious intent and above all protect SMEs increasingly exposed to economic crises and liquidity needs.
Exhibit 12
Uniting gatekeepers in the fightagainst illicit financial flows, via a
value-based Unifying Framework

Gatekeepers unifying framework - Illicit financial flows present one of the greatest obstacles to sustainable development. The World Economic Forum’s Gatekeeper Task Force, co-convened by the Forum’s Partnering Against
Corruption Initiative (PACI) and Global Future Council on Transparency and Anti-Corruption, developed a Unifying Framework that aims to equip gatekeepers from across sectors with the tools to more effectively identify
and respond to clients or transactions intent on furthering illicit activity. The framework consists of five corepractices and aspires to realize three fundamental principles within and across financial and non-financial gatekeeping industries worldwide.
All gatekeepers are invited to publicly endorse the Unifying Framework and to begin or continue to take concrete
steps toward its implementation.

Figure 16 – WEF, The Role and Responsibilities of Gatekeepers in the Fight against Illicit Financial Flows: A Unifying
Framework, June 2021

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B20 POLICY PAPER INTEGRITY & COMPLIANCE

Policy Action 4.3: Enhance power and independence of authorities
The sharing of up-to-date information on a timely basis regarding legal arrangements, in addition to preventing the misuse of bearer shares and nominee shareholders or directors at both the national and international levels
is critical. Prohibit bearer shares or at least adopt measures that allow for
the identification of the beneficiary of the shares such as requiring bearer
shares to be converted into registered shares dematerialization or requiring
bearer shares to be held with a regulated financial institution or professional intermediary immobilisation. Nominees should be required to disclose
their status upon the registration of the company and after being registered
as nominees. Nominees should be licensed and subject to strict anti-money
laundering obligations as well as regulating nominee shareholders or directors while fostering companies support into creating fairness through a setof common rules and standards levelling the playing field. In this sense, theestablishment of beneficial ownership transparency worldwide and the commitment of all companies to adhere to such mechanisms, contribute to creating fairness through a set of common rules and standards, levels the playing
field. Another key component is the independence of competition authorities, often defined as their distinct legal personality and structural separateness from Government. In addition to prescribing the authority’s structure,enabling legislation also usually gives legal meaning to the authorities’ operational (also known as functional) independence by prescribing functions,powers, the manner in which members of management and staff are to beappointed, their tenure and removal, and how the body is to be financed.
Networks of anticorruption authorities - During the last twenty years, about a dozen regional networks of anticorruption authorities have been set up. Anti-corruption authorities and their networks should be inspired by theexamples set by other accountability institutions, who’s global organisation, standardisation, accreditation, andpeer review have helped strengthen their independence and performance active.
The study highlighted the main international network of corruption prevention authorities as represented within
the below Figure.

Exhibit 13
Mapping Anti-Corruption

Figure 17 – U4 Anti-Corruption Resource Centre – Regional networks of anti-corruption authorities, 202053

B20 POLICY PAPER INTEGRITY & COMPLIANCE

Annex
Key Performance Indicators
Applied methodology & forecasting for targets definition
This section aims at describing the adopted methodology as well as the logic
behind the performed calculations and forecasting with regard to the target
definition of the KPIs.
Among the main variables chosen to perform the relative calculation, three
key pillars have been taken into consideration which lead the way in the definition of the settled target. In this context, these are (i) historical series ofdata used in forecasting, (ii) adjustment rate coming from post-pandemic
recovery effects, (iii) weighting the positive impacts as well as the ambition
that may result from effective implementation of the proposed recommendations and actions.
I. With regard to the adoption of historical data analysis, where applicable,
the performed activities involved the use of the delta (variation in percentage) derived from changes over the analyzed years to make predictions.
The abovementioned approach has been mainly used to define an accurate
growth rate and/ or decremental rate as well as gathering behavioural information for the relative indexes. To this end, it is relevant to say that theanalysis has been selected for a wider range of years to reduce and adjust
misleading data altered by pandemic effects.
II. As history shows, very often recovery periods coming after times of crisis,
are characterized by consistent bounce backs of e.g. economies and markets.
Nowadays in fact, due to the post-COVID-19 crisis massive cash injection
and strong evolutionary commitment will certainly have a solid impact on
the near future, seeing probably also a substantial focus on emerging themes
such as Integrity in business, ESG and sustainability.
III. The impact that the proposed recommendations and actions may have
has been used through weighing the rate previously identified therefore
positively adjusting the growth rate until reaching the forecasted target for
2024, by also strongly considering G20 members active participation. Obviously per each KPI, analysis has been carried out taking into consideration
the implementation of all the suggested measures, which if comprehensively
implemented the target ambition can be reached.

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Recommendation 1: Responsible conduct through the Procurement Cycle
The Global Corruption Index relies on two sub-indexes to measure corruption and white-collar crimes⁴⁰.
Global Corruption Index
Owner

GRP

Baseline (2020)

46%

Target (2024)

40%

Description

Four indicators are considered to measure corruption, weighted
as follows: i) The ratification status of key conventions (OECD,UN); ii) The level of perceived public corruption (Transparency
International’s Corruption Index, World Bank data, World Justice Project Organisation data); iii) The reported experience of
public and private corruption (Transparency International’s Global Corruption, Barometer, World Bank’s Enterprise Survey); iv) A
selection of country characteristics closely linked to corruption.
In addition, the index takes into consideration also White-Collar
Crimes extracting information i) the Basel Institute’s AML Indexand ii) the membership to FATF and / or related bodies.

Recommendation 2: Sustainable governance in business
The Business extent of disclosure index measures the extent to which investors
are protected through disclosure of ownership and financial information⁴¹.
The index ranges from 0 to 10, with higher values indicating more disclosure.
Global Corruption Index
Owner

World Bank

Baseline (2019)

6

Target (2024)

6,43

Description

The economic health of a country is measured not only in macroeconomic terms but also by other factors that shape daily economic
activity such as laws, regulations, and institutional arrangements.
The data measure business regulation, gauge regulatory outcomes,
and measure the extent of legal protection of property, the flexibility of employment regulation, and the tax burden on businesses. The
fundamental premise of this data is that economic activity requires
good rules and regulations that are efficient, accessible to all who
need to use them, and simple to implement. Thus, sometimes there is more emphasis on more regulation, such as stricter disclosure
requirements in related-party transactions, and other times emphasis is on for simplified regulations, such as a one-stop shop forcompleting business startup formalities. Entrepreneurs may not beaware of all required procedures or may avoid legally required procedures altogether. But where regulation is particularly onerous,
levels of informality are higher, which comes at a cost: firms in theinformal sector usually grow more slowly, have less access to credit, and employ fewer workers - and those workers remain outside
the protections of labor law. The indicator can help policymakers
understand the business environment in a country and - along withinformation from other sources such as the World Bank's Enterprise Surveys - provide insights into potential areas of reform.

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Key Performance Indicator
The Governance Score relies on two key elements: executive capacity andexecutive accountability⁴².
Although the index should be completed with all G20 members (counting at
the moment a total of 41 Countries - 12 being G20 Members), the proposed
KPI shows in the following table the relative ownership, the given baseline
and the 2024 target. Therefore, our ambition is to encourage governments
to ensure continuous improvement of this indicator.
Governance Score
Owner

SGI

Baseline (2020)

6,4

Target (2024)

7,1

Description

The following list represents the sub components of the two above
mention key elements: Executive Capacity i) Strategic Capacity;ii) Interministerial Coordination; iii) Evidence-based Instruments;iv) Societal Consultation; v) Policy Communication; vi) Implementation; vii) Adaptability; viii) Organizational Reform and Executive
Accountability: i) Citizens’ Participatory Competence; ii) Legislative Actors’ Resources; iii) Media; iv) Parties and Interest Associations; v) Independent Supervisory Bodies.

⁴⁰ Global Risk Profile, Global Corruption Index – available at: https://risk-indexes.com/global-corruption-index/
⁴¹ World Bank, Business extent of disclosure index – available at: https://data.worldbank.org/indicator/IC.BUS.
DISC.XQ?view=chart
⁴² Sustainable Governance Indicators, Governance Score – available at: https://www.sgi-network.org/2020/Governance56

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Recommendation 3: Cooperative compliance models and rewarding systems
The Countries with National Laws Protecting Whistle-blowers relies onwhistle-blower laws among different countries⁴³.
Governance Score
Owner

Environmental Law InstituteBaseline (2017)32

Target (2024)

54

Description

This index includes dedicated whistle-blower laws, as well as partial
whistle-blower protections included in criminal codes, laws regulating public servants, and company and securities law. It excludes
most other sector laws, including those related to health, safety,
and the environment, which represent an additional substantial
body of law in the United States. Because no single source consulted has compiled a comprehensive list of whistle-blower laws
worldwide, there may be additional whistle-blower provisions incountries not listed. Countries with dedicated whistle-blower laws
are indicated in the table.
i) Countries with dedicated national laws protecting whistle-blowers: Albania, Australia, Bangladesh, Belgium, Bosnia, Canada, Ghana, Hungary, India, Ireland, Israel, Jamaica, Japan, Liberia, Luxembourg, Macedonia, Malaysia, Malta, Mozambique,
New Zealand, Norway, Peru, Republic of Korea, Romania, Serbia,
Slovakia, Slovenia, South Africa, Uganda, United Kingdom, UnitedStates, Zambia.
ii) Countries with other national miscellaneous laws or provisions
protecting whistle-blowers: Argentina, Armenia, Austria, Brazil,
Chile, China, Cyprus, Czech Republic, Denmark, Estonia, France,
Germany, Greece, Iceland, Indonesia, Italy, Kenya, Latvia, Mexico,
Montenegro, Netherlands, Poland, Portugal, Russia, Sweden, Switzerland, Turkey.

Recommendation 4: Beneficial ownership Transparency
The Worldwide commitments and action - countries are fully committed to
Beneficial Ownership Transparency relies on open registers are in operation⁴⁴.
Governance Score
Owner

Open Ownership

Baseline (2020)

48

Target (2024)

83

Description

Countries have made commitments to beneficial ownership transparency, where open registers are in operation, and where OpenOwnership is providing support across the world

⁴³ Environmental Law Institute, Countries with National Laws Protecting Whistle-blowers – available at:https://www.whistleblowers.org/whistleblower-laws-around-the-world/
⁴⁴ Open Ownership, Worldwide commitments and action – available at:https://www.openownership.org/map/#map

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Schedule of Taskforce Exchanges
#

Date

Event

LocationTheme121-22 01/2021
		Inception 		
Meeting

B20 Kickoff

2
24/02/2021
		Conference 		Call I		

Review of 1 st Draft
of Policy Paper

3
24/03/2021
		Conference 		Call II		

Review of 2 nd Draft
of Policy Paper

4
28/04/2021
		Conference 		Call III		

Review of 3 rd Draft
of Policy Paper

503/06/2021
		Conference 		Call IV		

Review of 4 th Draft
of Policy Paper

Distribution of Members
Country# Country# Country# Country# Country

#

Italy

20 Turkey

6

Canada

2

Spain

1

Macedonia

1

USA

17

6

Global2

Pakistan

1

Jordan

1

South

2

South
1
Corea		

United1

BrazilUnited14 Switzer- 4
Kingdom		 land		

58

France11

China

MexicoAfrica		

4

Japan

2

India

1

10 Russia

3

Sweden1

Poland1Germany8

Belgium

3

Lebanon1

Finland1

Argentina

7

Australia

3

Ireland

1

Austria1

Arab Emirate

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Taskforce Members
NameCompany/Organization

Title

Country

Chair
Patrizia Grieco

Chairperson Of MonteDei Paschi Di Siena (MPS)

Italy

Deputy of the Chair
Valentino Ianieri

Monte Dei Paschi Di Siena
(MPS)

Italy

Co-Chairs
Katja Bechtel

PACI/WEF

Lead

SwedenMicheleCrisostomo

Enel

Chairman

Italy

Maria Fernanda
Garza

OrestiaCEO

MexicoKlaus
Moosmayer

Novartis

Chief Ethics, Risk &Compliance Officer

Germany

China Poly Group
Corporation

Chairman

China

Maria Fernanda
Garza

Members
Nicola Allocca

Autostrade
Per l'Italia S.p.A.

"Risk Management,
Compliance andBusiness Continuity"
Director

Italy

Daniel Alonso

Buckley LLP

Partner

United States

Patrick Amicucci

ElyfecPresident

FranceAmin Anchondo

Grupo San Marcos

CEO

MexicoFaisal Anwar

Independent Consultant Independent ConsulCompliance & Ethics
tant - Compliance &Ethics (Former Global
Chief Compliance
Officer of Habib
Bank Limited)

Pakistan

Yilmaz Arguden

Arge Consulting

ChairmanTurkeyDanela Arsovska

ICC Macedonia /Macedonian Chambers
Of Commerce

President

FranceRozemaria Bala

Snam S.p.A.

SVP Governance, Risk
& Compliance andSecretary of The
Board of Directors

Italy

59

B20 POLICY PAPER INTEGRITY & COMPLIANCE

Name

Company/Organization

Title

Country

Director

UnitedKingdom

Members60

Michael Barron

Michael Barron
Consulting Ltd

Alberto Bastanzio

Pirelli

Hakan Bekiroğlu

Tofas Turk Otomobil
Fabrikasi A.S.

Chief Legal Officer

TurkeyMartin BellThe Scotch Whisky
Association

DeputyDirector - Trade

UnitedKingdom

Nicole Bigby

Bryan Cave Leighton
Paisner LLP

Partner and GeneralCounselUnitedKingdom

Andrew Blasi

Crowell & Moring
International

Director

United Statesof America

Eduardo Patricio
Bonis

Navarro Castex Abogados

Partner

Argentina

Louis Bonnier

The Transnational
Alliance to Combat Illicit
Trade (TRACIT)

Directorof Programs

United Statesof America

Nicola Bonucci

Paul Hastings

Managing Director United States
Investigations andof America
ComplianceFrank Brown

Center for International
Private Enterprise

Director,
United States
Anti-Corruption & of America
Governance Center

Andrey Bugrov

MMC NORILSK NICKELMax
Burger-Scheidlin

ICC Austria - International Executive Director
Chamber of Commerce

Austria

Mark Butler

Nordic Investment Bank

Chief Compliance
Officer

FinlandIsabel Cane

Organisation for
Economic Co-Operation
and Development

Head, Trust in
Business

FranceDanielle Cannata

Saudi Basic Industries
Corporation

Senior Counsel

Saudi Arabia

Mark Carawan

IIA - Institute of Internal
Auditors

Member of the
Global Board

United Statesof America

Gabriel Cecchini

ESG Integridad

Director

Argentina

Italy

Senior Vice
President,
Sustainable
Development

RussiaB20 POLICY PAPER INTEGRITY & COMPLIANCE

Name

Company/Organization

Title

Country

Members
Roberta Codignoto
Emre Colak

ProIntegridade
Philip Morris Sabancı
Pazarlama ve Satış A.Ş.

BrazilEthics andUnited States
Compliance Cluster of America
Head for Turkey andMiddle East

Ligia Maura Costa

FGV EAESP

Christopher Costa

Tunitas Consulting LLC

James Cottrell

Holland & Knight LLP

Director

United Statesof America

Jan Dauman

IBLF Global

Chairman

UnitedKingdom

Grupo Sancor Seguros

CSR/Sustainability
Manager

Argentina

TERNA SPAHEAD OF CORPORATE AFFAIRS

Italy

Vincenzo Dell'Osso

Bonelli Erede Lombardi
Pappalardo

Senior Associate

Italy

Michel Demarre

SEFI- FNTP

Senior International
AdviserFranceMilosz Demczuk

Codewise

Chief Complianceand Strategy Officer

PolandHentie Dirker

SNC LAVALIN

Chief Integrity
Officer

CanadaChristina Eibi

Ludaciti GmbHFounder & CEO

Germany

Enrique Prini
Estebecorena

ALLENDE & FERRANTEABOGADOS

Sr Of Counsel
Compliance,
Sustainability &EnergyArgentina

Emily Farnworth

Hughes Hall, Cambridge
University

Deputy Director,
Centre for Climate
Change Engagement

UnitedKingdom

Cesar Ferreira

Grupo Hinode
Alliance for Integrity

COMPLIANCE
Officer

BrazilSusanne Friedrich

Alliance for Integrity

Director

Germany

Chartered Accountants
Australia New Zealand

Reporting &Assurance Leader

Australia

Betina Del Valle
AzugnaGiuseppe
Del Villano

Amir Ghandar

Full Professor

BrazilManaging Director United Statesof America

61

B20 POLICY PAPER INTEGRITY & COMPLIANCE

Name

Company/Organization

Title

Country

Corporate Internal
Audit andComplianceDirector

Italy

Members
Renzo Fubini

Laura Gimenez

Union Industrial Argentina Head of Social Policy

Argentina

Nicola Giovinazzi

Menarini

Corporate
ComplianceDirector

Italy

Calvin Goldman

The Law Office of Calvin
Goldman, Q.C.

Principal

CanadaEnrique Gonzalez

Studio Légale
Gonzalez Calvillo

Titulare

MexicoRenato Goretta

Gesta Srl

Presidente del CdA

Italy

Reynaldo Goto

BRF

Cheif Compliance
Officer

BrazilKaren Griffin

Mastercard

Alexander
Leonidovich
Gromov

Association of Industrial
Enterprisesof Saint-Petersburg

CEO

Russia

MEDEF

Senior Adviser

FranceKoç Holding A.Ş.

Deputy GeneralCounsel (senior
executive officer
responsible for legal
and compliancefunctions)

TurkeyUnilever

Global GeneralCounsel Anti-Corruption

UnitedKingdom

IFAC International
Federationof Accountants

Principal

United Statesof America

Grégoire Guinand
Rana Günay
HoffmanGonzalo Guzman

Scott Hanson

Maria Hernandez

62

A. Menarini IFR

Executive Vice
United States
President and Chief of America
Compliance Officer

Eversheds Sutherland & IE Partner Compliance
University/ Academic Director
Master Global
Corporate
Compliance LLM

Spain

B20 POLICY PAPER INTEGRITY & COMPLIANCE

Name

Company/Organization

Title

Country

Members
Robin Hodess

The B Team

Director
United Statesof Governanceof America
and Transparency,
The B Team

Laura Gimenez

Novartis International AG

Global Head Policy, Switzerland
Advisory &Anti-Bribery program

Nicola Giovinazzi

Australian Bar

Senior Counsel

Australia

Calvin Goldman

United Nations
Development Programme(UNDP) [UNDP FairBiz
Integrity Hub]Business Integrity
AdvisorThailand

Enrique Gonzalez

Hikma Pharmaceuticals plc Group Compliance
Officer,
Global Operations

JordanRenato Goretta

Magazine Luiza

Reynaldo Goto

Global CompetitivenessEmpowerment
Forum (GCEF)

Karen Griffin

SUEK

Chief Compliance
Officer

RussiaAlexander
Leonidovich
Gromov

Nokia

Supplier
Anti- Corruption
Head

Finland

Grégoire Guinand

SAFRAN and MEDEF
and BIAC

Senir VP Group
Compliance Officer

FranceRana Günay
HoffmanCercle d'Ethique desAffaires

ChaimanFranceGonzalo Guzman

Maruti Global

Head of Risk
Management& Internal Controls| Data Protection
Officer

BrazilFounder andKorea South
Executive President

Executive Chairman South Africa

Scott Hanson

Engaged Consulting Ltd

Director

UnitedKingdom

Maria Hern

SOFIDEL SPA

CEO

Italy

Robin Hodess

Grace Li

GSK Consumer Healthcare Compliance Officer
Italy
ICC China

ICC China

UnitedKingdom
China

63

B20 POLICY PAPER INTEGRITY & COMPLIANCE

Name

Company/Organization

Title

Country

Members
Yongyuan Li

Yingke Law Firm

Partner

China

Paulo Lino

Texan Chamberof Commerce in Brazil

Institutional
Representative

BrazilIndein my own name

Argentina

SebastianDr. Lochen

thyssenkrupp AG

Group GeneralCounsel (acting) /Chief Compliance
Officer

Germany

Yinhong Lu

Xiaomi Corporation

Senior Director of
Legal Department

China

S.A.M. srl

Responsabilerelazioni esterne
e comunicazione

Italy

David Luna

Luna Global Networks

Luna Global
Networks

United Statesof America

Emanuel Macedode Medeiros

SIGA (Sport Integrity
Global Alliance)

Global CEO

Switzerland

Daniel Malan

Trinity College Dublin

Assistant professor inbusiness ethics

Ireland

Elena Mannucci

Termisol Termica S.r.l.

Legal, Complianceand CSR Manager

Italy

Sihle Mdluli

Bushveld Minerals

Director: Strategy
and Corporate
Services

Guernsey

Lisa Miller

World Bank Group

Head, Integrity
Compliance

United Statesof America

Maria Molino

HSBC Italy

Head of Regulatory
Compliance, Italy

UnitedKingdom

Cecilia Müller
Torbrand

Maritime Anti-Corruption
Network

Executive Director

Denmark

Yann N'Diaye

Investissements &Intermédiation en Banqueet Financements (IIBF) SAS

Président

FranceMasanori Nagata

PANASONICCORPORATION

Chief Advisor,
Legal & Compliance
DivisionJapan

Georg Neumann

Open ContractingPartnershio

Head ofCommunications

United Statesof America

Virginia Linaza

Beatrice Lucarella64

B20 POLICY PAPER INTEGRITY & COMPLIANCE

Name

Company/Organization

Title

Country

KEIDANREN(Japan Business
Federation)

Deputy Director,
SDGs Promotion
BureauJapan

East & Concord Partners

Partner

China

Transparency
International

Lead Global Business
Integrity Programme

Germany

Bundesvereinigung
der Deutschen
Arbeitgeberverbände(BDA)

Deputy Director

Germany

Jeffrey Owens

EY

Senior policy advisor
to the Global vice
Chair tax

UnitedKingdom

Cosimo Pacciolla

Kuwait Petroleum
Italia spa

Legal Manager

Italy

Rocio Paniagua

Transparency
International UK

Head of Business
Integrity

UnitedKingdom

Rober Papp

General Electric

Chief Corporate United States
Compliance Officer of America
Middle East Africa

Members
Emiko Nagasawa

Xudong Ni
Britta Niemeyer

Paul Noll

Richard Parlour

Financial Markets Law
International

CEO

UnitedKingdom

Oliver Peltzer

Arnecke Sibeth Dabelstein

Partner

Germany

Gigante Restaurant GroupCSR VP

MexicoSiemens Spa

President & CEO
Siemens Spa

Germany

Claudio Giovanni
PicechJulia Pilgrim

United Nations Office on Crime Prevention
Drugs and Crime
and Criminal Justice
Officer, Corruption
and Economic Crime
BranchGlobalKenneth Resnick

ATRQ Global LLC

President

United Statesof America

Giovanna
Ricuperati

MULTI Consult srl

Amministratore
Unico

Italy

Business at OECD (BIAC)

Acting Secretary
GeneralFranceRINA S.p.A.

Charman & CEO

Italy

Hanni Rosenbaum

Paolo Salza

65

B20 POLICY PAPER INTEGRITY & COMPLIANCE

Name

Company/Organization

Title

Country

Members
Fadi Saab

Trans Capital Finance

Chairman & CEO

UnitedKingdom

Ina Sandler

Business at OECD (BIAC)

Policy Advisor

FranceChe Sidanius

Refinitiv

Global Head ofFinancial Crime andIndustry Affairs

UnitedKingdom

Denis Simonneau

L'OréalSenior Vice
President in chargeof Institutional
RelationsFranceAlejandro Simon

Grupo Sancor Seguros

CEO

Argentina

Kim Smouter

ESOMAR (World
Association for Market,
Opinion and Social
Research)

Head of Public
Affairs andProfessional
Standards

Netherlands

Andy SongeNotus InternationalPeter Spivack

Hogan Lovells

Partner; specialist
in anticorruption
enforcement,complianceand remediation

United Statesof America

Paolo Tarchioni

Biesse S.p.A.

Biesse S.p.A.

Italy

Daniel Trujillo

WalmartAnny Tubbs

First Move Productions

Anna Tunkel

APCO Worldwide Inc.

Nick van
Benschoten

UK FinancePrincipal, Economic
Crime Policy

UnitedKingdom

Luca Vavassori

Eni S.p.A.

Head of Integrated
Compliance

Italy

Ava Firm, SC.

Managing Partner

MexicoAgustin Valazquez

66

Advisor Head of United States
Artificial Intelligence of America
research

Global Chief Ethics United States
and Complianceof America
Officer
Co-Founder

Belgium

Senior Vice
United States
President, Headof Americaof Global Strategic
Initiatives &Partnerships

B20 POLICY PAPER INTEGRITY & COMPLIANCE

Name

Company/Organization

Title

Country

LUCANO 1894 srl

CEO

Italy

Xinrui Wang

Anli Partners

Senior Partner

China

Richard Woods

World Benchmarking
Alliance

EU Public
Policy Lead

Netherlands

Alexandra Wrage

TRACE

President

United Statesof America

King & Wood Mallesons

Partner

China

TEID Ethics andReputation Society

Secretary General

TurkeyInternational Chamberof Commerce UK (ICC)

Policy CoordinatorFranceFangda Partners

Partners

China

MIN YUICC China

Director General

China

Kai Zhang

China Communications
Construction Company

Business Manager

China

Siemens AG

Vice President,
Legal andCompliance, Headof Collective Action

Germany

Members
Francesco Vena

Wei WuNeslihan Yakal

Katie Yan

Yunxia (Kate) Yin

Sabine Zindera

Coordination Group
Name

Function

Company/Organization

Antonio Matonti

B20 Task Force Manager

Confindustria

Alessia Bausano

B20 Task Force Manager
AssistantConfindustria

Annarita Sofia

B20 Task Force Manager
AssistantConfindustria

Cosimo Pacciolla

B20 Task Force - Special
Advisor

Kuwait Petroleum Italia spa

Francesco Iervolino

B20 Secretariat

Confindustria

Matteo Corsini

B20 Secretariat

Confindustria

Barbara Jesari

Knowledge Partner

EY

Fabrizio Santaloja

Knowledge Partner

EY

Piero Di Michele

Knowledge Partner

EY

67

B20 POLICY PAPER INTEGRITY & COMPLIANCE

Coordination Group
Name

68

Function

Company/Organization

Domenico Galimi

Knowledge Partner

EY

Pierclaudio Crecco

Knowledge Partner

EY

Eleonora Toscano

Knowledge Partner

EY

Rossella Sabia

Scientific Partner

Luiss

Antonella Sciarrone
Alibrandi

Scientific Partner

Università Cattolicadel Sacro Cuore

Hanni Rosenbaum

Network Partner

BIAC

Ina Sandler

Network Partner

BIAC

Margaret Cowan

Network Partner

PACI/WEF

Gemma Aiolfi

Network Partner

BASEL GOVERNANCE

Katie Yan

Network Partner

ICC

Scott Hanson

Network Partner

IFAC

B20 POLICY PAPER INTEGRITY & COMPLIANCE

An initiative byKnowledge partners

Network partners

Scientific partners

70