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What happens if a member is involved in corruption and or misconduct allegations?
Bribery and corruption allegations can be complex, sophisticated and are not always accurate. TI Australia aims to address allegations of corruption involving members in an objective manner. TI Australia will take all necessary steps to protect its reputation as the leading global anti-corruption organisation.
In response to allegations of bribery, corruption and misconduct, TI Australia will:
- Contact the member directly to discuss the alleged circumstances.
- Undertake its own verification and checking process. Considerations include: the scope of the allegation (i.e. an isolated incident or a widespread or repetitive problem), the amount(s) involved, the degree of knowledge and involvement by the member company, due diligence including risk identification, management and preventative arrangements, the corrective actions in place and the willingness of the company to cooperate with TI Australia and other investigators.
- Consider whether the allegation, or the member’s responsiveness to the allegation, conflicts with TI Australia’s Membership Principles, strategic objectives and Ethical Collaboration Policy.
- If yes, TI Australia’s CEO will issue written communication to the organisation outlining TI Australia’s concerns, requesting further information and a formal meeting to review the allegation and the member’s intended response.
- Assess the explanation provided by the member and may conclude that the member’s response is:
- Satisfactory – no further action is necessary;
- Not satisfactory – but may be rectified with a short-term action plan for improvement and monitoring; or
- Not satisfactory – the Suspension or Termination of TI Australia Membership procedure is initiated.
TI Australia undertakes to keep details confidential while these discussions are underway.
If the organisation is not willing to engage, or engages in a manner that is deemed by TI Australia to not be genuine, or the situation poses a risk to the reputation of TI Australia, membership may be suspended or terminated. At this stage TI Australia will publish the change in membership status on the TI Australia website, and may disclose details to other stakeholders, including the media.
Suspension or Termination of TI Australia Membership
TI Australia will suspend or terminate a membership where the reputation of TI Australia is put at risk or where the organisation has not demonstrated commitment to genuine remedial reforms.
A company may also be suspended in case of persistent non-compliance with its other commitments (e.g. payment of the membership fees, compliance with the rules on the use of the logo, adoption of a program to combat corruption within an agreed timeframe etc). Suspension, termination or exclusion of membership could occur if the company is directly or indirectly linked to causing or contributing to adverse impacts that contradict the values and principles of Transparency International including respect for human rights.
Suspension is usually for 12 months, and termination for 24 months but may be extended by the TI Australia Board.
The decision to suspend or terminate will be taken by the TI Australia Board in a timely manner after assessing the seriousness of the allegation and any remediation evidence available. TI Australia will write to the member organisation’s CEO or relevant contact to convey its decision and the reasons for that decision.
During the nominated period, the suspended member cannot attend member events, their name will be removed from the public list of TI Australia members and they must remove references on their own website (or elsewhere) of its support for TI Australia. Donations (financial and in kind) by the organisation to TI Australia will cease for the suspension period. These restrictions will be ongoing for terminated members until such time that their re-application for TI Australia Membership is accepted.
An organisation may re-apply for TI Australia Membership when the TI Australia Board determines that a suitable period of time has elapsed, and may be re-admitted in accordance with the due diligence and screening for new members.
TI Australia reserves the right to comment publicly on investigations of alleged breaches of the Membership Principles, allegations of corruption against a member, and the suspension or termination of an organisation’s membership.
For the full process for management, please review the Management of Corporate Integrity Breaches Process.
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