MACN's Pillars: The Three C's

MACN works towards its vision through objectives and goals divided into three pillars: 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 Actions

At the core of MACN’s work to improve the operating environments for member companies are collective actions, through which member companies unite with stakeholders including port and customs authorities, NGOs, and local governments to implement a range of programs to tackle corruption in ports. Due to the volume of world trade that passes through ports, anti-corruption initiatives targeting ports can have an impact on a wide variety of different industries and across supply chains and societies. 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. As such, key stakeholders are involved in both assessing the challenges and devising the solutions. Overall, MACN´s collective actions implemented to date have proven to be an impactful, effective, and cost-efficient way to promote trade and transparency and to drive private sector leadership on combating corruption and bribery in the port and maritime sector. Below we present case studies from MACN´s collective action projects in Nigeria, Argentina, Indonesia, and Egypt, illustrating the activities implemented and the results achieved to date by the network.

Capability Building

MACN’s Anti-Corruption Principles

MACN is comprised of like-minded companies dedicated to promoting compliance with anti-corruption laws and committed to the elimination of corrupt practices. MACN members are committed to implement the MACN anti-corruption principles as part of their overall compliance program.

 

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

MACN members recognize that it is the culture that governs deep-seated change. By working explicitly on integrity culture programs, MACN will ensure a long term, sustainable change of mindset across the industry, laying the groundwork to realize its vision. Objectives under this pillar include: 

  • Promoting an open dialogue amongst members and across the industry on integrity issues
  • Raising awareness across the industry and value chain on integrity issues impacting the maritime industry
  • Collaborating with key stakeholders and interest groups in developing and promoting integrity culture programs