Case Study: CSR uses UK Bribery Act as positive business opportunity

Leading wireless technology supplier CSR (Cambridge Silicon Radio) plc partners with SAI Global to deliver key components of their holistic anti-bribery programme to communicate and enforce a zero tolerance stance on bribery & corruption.

 

Background

Due to the nature of the business and the geographical locations in which it operates, bribery and corruption could pose a significant threat to CSR. Senior executives used the timescale for the enforcement of the UK Bribery Act 2010 as a positive business opportunity, taking the time to review their anti-bribery programme and conduct a risk assessment on which to base their response to the incoming legislation. This review highlighted a need for training and awareness across the group.   SAI Global were selected to help develop a multi-stranded education programme incorporating online learning, facilitated workshops and a train-the-trainer programme to help cascade the programme throughout all geographic locations. A whistleblowing hotline and case management system was also provided by SAI Global to give CSR employees a secure and confidential means of reporting any suspected wrongdoing and the company an efficient system for managing reports through to resolution.

Education and Training - a Multi-Stranded Approach

Taking their anti-bribery risk audit as a starting point, CSR embarked on a project to deliver a comprehensive anti-bribery training and education programme throughout the entire organisation. A clear objective of the training was to enable all employees to understand the impact of the incoming legislation for them as individuals and to reinforce CSR's zero tolerance stance towards bribery and corruption. This was achieved by providing thought-provoking, reflective content that was not only relevant to CSR as a business, but also relevant to employees' daily job roles.

'Based on our audit, we fully understood the risk-profile of CSR', explained Ian Purdie, Learning & Development Manager at CSR. 'We knew exactly how many people we had in what sort of roles and in which locations, and we discussed how our training and education could achieve the necessary positive impact - not just now but on an ongoing basis'.

CSR elected to combine three different strands of learning - online learning for all employees, facilitated workshops for managers and employees in high risk functions or regions, and a trainer programme designed to create a cohort of people around the world who would be able to deliver the facilitated workshops for future initiatives.

Targeted, Tailored Online Learning

SAI Global's online learning programme 'Preventing Bribery and Corruption' was selected by CSR and customised to incorporate images, graphics and terminology that would immediately resonate with employees. The content was also reviewed to ensure it was relevant to the industry in which CSR operates and additional scenarios or 'lessons' were developed by SAI Global managers to help employees spot potential red flags in situations that they could relate to. The course also enabled learners to be profiled prior to starting the programme so that the content and lessons they received were relevant to their job roles.

'The need for online learning surfaced very quickly during our discussions', said Ian Purdie, 'however it was widely recognised that this would have to be high quality online material. It needed to be targeted and it needed to be tailored. This meant that the particular message employees received was relevant to them so they would have the confidence and knowledge to conduct themselves entirely in line with the requirements of the legislation'.

The online learning has been rolled out to CSR's 1,750 employees around the globe and within just 4 weeks achieved a completion rate of 89%. 'There is some very dull compliance learning out there', said Ian Purdie, 'but I have had a significant number of people contact me to say they think the SAI Global material is really good. To get spontaneous feedback like that is worth a lot'.

The company is just about to embark on a second roll-out on a similar scale to the first to ensure that employees within a newly-acquired business also understand CSR's commitment to an anti-bribery culture as well as their own responsibilities for preventing and rejecting bribery.

Facilitated Workshops

To run alongside the online learning, SAI Global worked with CSR to customise workshop materials for employees and managers in high risk roles or territories. The workshops incorporated CSR's policies and procedures including issues such as gifts, hospitality and entertainment, facilitation payments and whistleblowing and gave employees the opportunity to discuss practical implications for compliance and enforcement. 'We wanted to give people the opportunity to really explore the issues surrounding bribery and corruption in more thought-provoking sessions', explained Karen McKeever, Head of Organisational Development at CSR. 'We wanted to partner with somebody that could come into the organisation and could generate discussion, get people to think about things and then apply their knowledge to their own situations to empower them to make the right decisions'.

The workshops were delivered by one facilitator, who completed a gruelling itinerary covering 19 ½ days of workshops in 9 different countries in Europe the US and Middle and Far East, including UK, USA, China, India and Japan. Train-the-trainer sessions were also carried out at each site to provide the skills locally to repeat the workshop training as necessary e.g. for new starters. The decision to use just one facilitator was one which caused some debate as Ian Purdie explains.

'We decided to have one person deliver the workshops, despite the obvious logistical challenges this created, as it allowed that person to really understand CSR's culture. It also meant that feedback from one session could easily be used to enhance future sessions so that scenarios and examples used throughout the workshop programme became ever more plausible, ever more realistic and therefore ever more effective.'

Getting the buy-in of local people on the ground at each site was crucial to the success of the workshop programme, not just to ensure that everything clicked into place from a logistical point of view, but also to give the sessions more credibility. Each workshop session was attended by the local office leader who would be able to help ensure that the message was delivered in a local form of words and in a way that employees would respond to. Getting the input of local people with local knowledge and engaging them throughout the process helped CSR to understand and overcome any cultural differences that may have negatively impacted the effectiveness of the training.

Whistleblowing Hotline and Case Management

As part of the their broader anti-bribery programme, CSR took the decision to up-grade their existing whistle-blowing hotline facility by using SAI Global's ethics reporting hotline and case management system. This provides employees with a secure and confidential reporting system where they can log any suspected wrongdoing. As Karen McKeever explained however, there is no history of ethical incidents within CSR. Employees are more likely to consider blowing the whistle on competitors who are gaining competitive advantage by continuing to pay bribes in some locations.

'As a business we are committed to taking an ethical stance on bribery in all its forms. At the workshops some of our employees expressed concern that we would be disadvantaged by enforcing this approach however we took this as an opportunity to underline our commitment and to emphasise that people can record their concerns - that they do have the choice to take action'.

Key Successes of the Project to Date

In addition to the quick take-up of the online learning and the positive reaction of those who have completed it, there are a number of indicators within CSR that the multi-stranded training is already impacting behaviour, that people understand bribery and corruption is a serious issue and they are in no doubt as to the company's position on it. The fact that it has become a 'water cooler' topic of debate illustrates that there is increased awareness of and interest in the topic. There are also many examples of employees making small changes to daily work practices. Perhaps the most interesting development however is that the training is starting to get people to think differently.

'We are a technical organisation', said Karen McKeever, 'and as such we are used to training being quite cut and dried - instruction to go away and implement. But of course you can't do that with anti-bribery compliance training. You have to give people the knowledge they need to make the right decisions for themselves'.

Key Success Criteria for Effective Anti-Bribery Programmes

  • Get the buy-in of the Board and senior management. CSR's Board were committed to the programme from the outset and much of the training and on-going communications were endorsed by the CEO personall
  • Line up all your policies and processes so you understand all the touch points within your business that will be impacted by the programme
  • Decide from a business point of view what you are and are not prepared to do and align your policies, controls and training accordingly. For example, are you prepared to turn down work because you're not prepared to be bribed?
  • Identify and form relationships with other stakeholders within the business whose cooperation you will need. In CSR's case there is a well-established model for forming cross-functional teams and adopting a collaborative approach across departments. In this case the key contacts were CSR's legal team, HR, IT and internal communications
  • Use local knowledge to avoid cultural and legal barriers that could negatively impact multi-territory programmes
  • When implementing training, identify the needs of the various audience groups within your business and ensure they receive content that is relevant to their roles and delivered in the appropriate format
  •  Don't underestimate the importance of an on-going, consistent internal communications to support and reinforce your programme
  • Select a partner who has the scale, scope and expertise to understand and meet your business objectives

ABOUT CSR

CSR is a global provider of innovative silicon and software solutions for the location-aware, media-rich, cloud-connected world. The company's platforms are optimised for the automotive navigation and infotainment, digital cameras and imaging, connected home infotainment and wireless audio markets. CSR provides solutions to complex problems in the audio-visual, connectivity and location technology domains across a broad range of markets, with a technology portfolio that includes GPS/GNSS systems, Bluetooth, Wi-Fi, FM, NFC, aptX and CVC audio codecs, JPEG, MPEG, H.264 imaging, IPS printing, microcontrollers, DSPs and broadband receivers. CSR's technology solutions and market platforms enable its customers to deliver a superior user experience and are adopted by leaders in the auto, computer, home and mobile markets. More information can be found at www.csr.com.