MACN's Pillars: The Three C's

MACN works towards its vision through three objectives that are elaborated in the MACN Mission: Capability Building, Collective Action, and Culture of Integrity.

 

Capability Building

Providing industry-leading innovative solutions to our members

Collective Action

Driving and leading sustainable change in the operating environment

Culture of Integrity

A recognised contributor to integrity standards in the industry and society

 

 

Collective Action

What is Collective Action and why is it important?
Collective action is an important tool to help the private sector take proactive steps to tackle corruption. Tackling systemic integrity challenges requires collective action, with companies joining forces and sharing information and approaches, but also engaging governments and civil society. The essence of the MACN collective action approach is that successful, lasting changes in the operating environment will take effect only if they are enabled and supported by and beneficial to key stakeholders. Through collective action, MACN members work in partnership with local authorities to develop solutions that are both beneficial to all and realistic to implement.

In MACN collective action projects, member companies unite with stakeholders including port and customs authorities, NGOs, and local governments to undertake root cause analyses and then implement a range of ’recommended actions’ that tackle corruption in ports and across the maritime supply chain.

What are the outcomes?
MACN’s collective actions have generated major outcomes, including for example: reductions in demands for facilitation payments in the Suez Canal; new regulations in Argentina that make it more difficult for officials to demand bribes; and improved ease of operations in Lagos, Nigeria, with the implementation of standardized operating procedures and grievance mechanisms.

Capability Building

What is Capability Building and why is it important?
In order for captains of ships and other private sector actors to be able to say no to demands for facilitation payments, they must feel supported by strong policies and principles. MACN provides a safe forum for engagement through which members can share challenges and best practices, collectively assessing the areas for improvement in their internal procedures and approaches and developing open-sourced solutions.

Following the MACN Anti-Corruption Principles, MACN develops shared methodologies, frameworks, trainings, and campaigns, helping each member company to strengthen its approach to tackling corruption.


What are the outcomes?
Together with GAN, MACN developed and launched a training toolkit on anti-corruption and integrity in the maritime industry, containing material for running training workshops and e-learning modules.

 

The Seven Principles

 
Compliance Program Requirements
Members should create and maintain an anti-corruption compliance program that reflects and is designed to address the risks pertinent to the company’s business.

Senior management and/or the Board of each Member should give explicit and visible support to the anti-corruption compliance program.

Members should confer responsibility for the anti-corruption compliance program on trustworthy officers who are sufficiently independent and empowered to fully implement the program.
 
Proportionate Procedures
Members should have clearly articulated policies and procedures that comply in full with the laws which apply to them and, as a minimum, prohibit all forms of corruption and give specific guidance on facilitation payments with the ultimate aim of their elimination.

The policies and procedures should be proportionate to the risks faced by the various parts of each Member, as well as the nature, scale and complexity of the organisation's activities, and should apply to all employees as well as third parties that act on behalf of the Member.
 
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Risk Assessment
Members should assess external and internal corruption risks on a regular basis and document their findings.
 
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Training & Communications
Awareness of policies and procedures should be reinforced through communications and training to employees and, where appropriate, third parties. A record should be kept of all training provided.
 
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Monitoring & Internal Controls
The anti-corruption compliance program should include features designed to prevent and detect incidents of bribery, facilitation payments and other forms of corruption through appropriate monitoring and auditing protocols.

Internal controls should be implemented to protect the integrity of financial and accounting procedures such that the company keeps fair and accurate books, records and accounts.

The program itself should be audited regularly and improved or updated as necessary.
 
Reporting, Discipline & Incentives
Members should provide employees with access to methods for asking questions and/or reporting concerns. Those asking questions or reporting concerns in good faith should be able to do so without fear of retribution.

Members should investigate credible reports of improper behavior and should implement appropriate corrective actions when necessary.

Compliance with the anti-corruption compliance program should be encouraged through incentives for proper behavior and, where necessary and appropriate, enforced through discipline for improper behavior.
 
Due Diligence
Members should conduct risk-based due diligence on counterparties as well as in respect of the hiring and oversight of third parties and business partners. The due diligence should include an anti-bribery commitment from third parties.
 
 

Anonymous Incident Reporting Mechanism

In order to identify collective actions, MACN has set up a unique Incident Reporting Mechanism that assists in identifying areas for collective actions.

Reporting Goals:

  • For members to be able to safely and anonymously report their anti-corruption challenges within the Network and provide best practice solutions.
  • To identify areas for collective action with various external stakeholders to address root causes

 

Culture of Integrity

What is Culture of Integrity and why is it important?
Culture of Integrity is an attempt not just to generate change for specific stakeholders (e.g. captains or port authorities) in specific corruption hot-spots, but to drive fundamental change in deep-seated attitudes regarding corruption, creating a permanent trend towards the eradication of demands. 

While it is vital to address both internal capacity to reject demands and specific geographic areas and actors that cause problems for shipping companies, MACN members recognize that culture governs deep-seated changes. To achieve its vision of a maritime industry free of corruption, MACN must reach out beyond its membership and collective action stakeholders to all actors in the maritime industry, and ensure alignment on anti-corruption thinking.

 

What are the outcomes?
This pillar was introduced in 2017. MACN anticipates the following outcomes:

  • The development and implementation of Integrity Culture training across the MACN Membership
  • Implementation of MACN training or integrity culture training in key stakeholder and interest groups