In a recent roundtable as part of the World Bank Office of Suspension and Debarment’s Fifth International Debarment Colloquium, panelist Joseph Mauro (an Integrity Compliance Specialist with the Bank’s Integrity Vice Presidency (INT)) discussed efforts to move from a “stick” to a “carrot” approach with respect to corporate compliance programs.
Under the Bank’s current system, while implementation of a compliance program is a remedial measure for which mitigating credit may apply, individuals within the Integrity Compliance Office were rarely involved in reviewing a compliance program to any significant extent until after a company has already been sanctioned. Under this process, a company’s compliance program was typically reviewed in-depth only as a condition for release from sanction.
Mr. Mauro described a new initiative, which has been ongoing for the past 6-12 months, under which the Bank hopes to incentivize companies to adopt compliance programs prior to allegations of misconduct. Under the new system, the Integrity Compliance Office will work with INT investigators to perform a thorough compliance program analysis before a company is sanctioned to determine whether mitigation is warranted.