Incorporate integrity principles into onboarding, employees’ development and third party management –
Employees and third party compliance

By employing the right persons, the company will make sure that it continues to promote its fundamental values and enable the development of an ethics culture, with which it supports the realisation of its mission and long-term success. For this purpose, leaders should make sure that interviews and due diligence on prospective employees and contractors include checks of their background and their awareness of ethics and integrity, as well as their relevant past behaviour. More in depth due diligence should be applied to jobs, positions and contractors, which are identified as posing a higher compliance and ethics risk.

Training in business compliance and integrity should be provided on a regular basis and should include certification for all directors, managers and employees, including important contractual partners. Content of the training should be accessible to all employees in the local language. It should include all relevant examples of difficult situations, which could occur given the specific circumstances of the company, as well as cases of desired action and best practice.

Training programmes should include a mix of live interactive sessions lectures or workshops, serious plays, on-line modules, written documentation, and a website with a collection of resources, educational video clips, and Frequently Asked Questions (FAQs).


While contractual partners, supplier and other third parties carry the reputation of their clients in their hands, companies are still not sufficiently aware of the reputation of these partners and their networks of business relationships.


Recommended indicators for the fourth principle

Indicators proving that the principle is implemented in business operations:

  • The company has developed and actually implements employees’ background due diligence procedure in terms of compliance and integrity, before they are employed and periodically, specifically including the high-level staff and high-risk contractors.
  • The company has a training plan addressing specific compliance and integrity risk areas, including a definition of the target audience, frequency, methods, such as e-training, workshops, etc.; and the manner of confirmation of attendance and conclusion of education.
  • A training programme has been developed for all levels of leadership; also determining the general and specific risk topics, objectives of the training, the timeline and the manner in which feedback is gained to examine the effectiveness of the training.
    This is an integral part of the onboarding protocol and is mandatory.
  • The company also has a programme of compliance and integrity education and training, for individual target groups; specifically designed to cover relevant areas of work, business functions, groups of employees and other contracting parties in high-risk positions.
    Training is focused on specific relevant risk areas, with examples of scenarios of violations and correct conduct included; the program also includes the manner in which participation is confirmed and the training is concluded; it must reach at least 80% rate.

Indicators proving that the leadership is making progress in implementing the principle in the company’s business practices:

  • What is the leadership and management attendance rate for compliance and ethics training?
  • What is the employees’ attendance rate for the training?
  • What is the proportion of successfully completed employees’ training and of employees’ certification about completing and understanding the training?
  • Do all important contractors and contractors, which perform high-risk tasks attend compliance and integrity training before they sign a contract?
  • How many times had the company rejected a new employee or a contractor for integrity-related reasons?