Introducing: The "conscience in your pocket"


By Samantha White

Have an ethical dilemma? There’s now an app for that.

The Institute of Business Ethics (IBE) on Tuesday launched a free mobile-device app and online toolkit to provide employees with immediate guidance on a range of scenarios from accepting gifts and hospitality to conflicts of interest. 

The launch comes on the heels of an IBE survey, which shows that bribery, corruption and facilitation payments remain the most significant ethical issue for 80% of respondents from FTSE 350-listed companies. 

Through the app, employees facing a dilemma can answer a series of questions to determine the appropriate conduct in a particular scenario. The content focuses on anti-competitive behaviour and situations covered by the UK Bribery Act. 

The IBE version of the app is believed by some to be the first of its kind. 

It was developed by the IBE in partnership with Serco Group, an international service company with more than 100,000 staff. At a London launch event, Robert Smith, Serco’s director, business compliance and ethics, said that he identified a need within his own organisation for detailed guidance on how to deal with specific situations such as handling requests for facilitation payments (a type of bribe sought to speed up an existing duty), when and how to say no, and what to do following such a request. Smith envisaged it as a practical toolkit of resources to help frontline employees, particularly in high-risk areas. The company rolled out the branded and customised version of the app as a forced download onto corporate mobile devices through AirWatch, a mobile device management app.

For Serco, the critical driver was making the app accessible when needed. Therefore, the information is held on the device and does not depend on an internet connection. Where further guidance is needed, the Serco-branded version refers the user directly to the relevant contact within the organisation. 

There is potential for the app and toolkit to be used internationally, particularly since the UK Bribery Act has extra-territorial reach for companies registered in the UK. For a fee, organisations can work with the IBE to customise the app to reflect their own operational procedure, for example, gift thresholds, reporting policies and the relevant person to contact in a given situation. 

Tate & Lyle, a London-based multinational that makes specialty food ingredients, is working with the IBE to develop a version that is tailored to the company’s needs. It will be rolled out to all staff who deal with Tate & Lyle’s customers, suppliers and other business partners. The company plans to translate the content of the app into Russian and Mandarin Chinese, and possibly Spanish, to serve its global workforce. Alyson Corrigan, global director of ethics at Tate & Lyle, said that although the app was developed around the UK legislation, the spirit of laws and regulations across the world are similar. 

Delegates at the launch observed that to ensure take-up of the app and for it to meet its objective of helping employees make the right decision in difficult situations, organisations need to take appropriate action when unethical behaviours come to light, demonstrating to employees and stakeholders that unethical practices will not be tolerated. 

David Pitt-Watson, executive fellow, London Business School, heralded it as “a sensible, practical development taking the business world forward.” The portability of the app prompted Harriet Kemp, head of engagement, IBE, to liken it to “a conscience in your pocket.” 

CGMA designation holders must also consider and comply with their employer’s policy as well as the code of conduct of the membership organisation to which they belong, whichever is more restrictive. For example, in the US, a CGMA designation holder who is a member of the American Institute of CPAs (AICPA) must comply with requirements set out in the AICPA Code of Professional Conduct on gifts and hospitality as well as any rules their state board of accountancy may have on the matter.  

Samantha White (swhite@aicpa.org) is a CGMA Magazine senior editor.