Topic: Corporate anti-corruption and compliance in global governance from a practice based approach: Focus on experts rather than the company.
Anonymity: Yes
Confidentiality agreement: Yes Recorded: Yes
Withdrawal: At any time before, during, or after the interview.
Round 1:
1) Can you describe or define anti-corruption in your own words?
2) Do you see corporate anti-corruption as part of the broader CSR agenda?
3) Who or what are the main drivers behind the recent turn towards compliance in the private sector?
4) Based on your experience, can you describe to me how Danish companies feel about/responded to the need to implement anti-corruption?
5) Who or what would you say are the main actors shaping the anti-corruption agenda?
6) Can you talk to me about private to private or private to public cooperation against corruption? 7) How do companies control compliance abroad and in particular China? Established
department there?
8) What are the obstacles when implementing anti-corruption/compliance measures in China? a. Third party management
b. Training
9) By what standards CoCs are being designed and drafted?
10) What is the objective the company tries to accomplish through the COC? 11) What capacities do you want to strengthen to your employees with training?
a. In house or external private consultancies?
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Round 2:
1) How would you describe corporate anti-corruption? a. Ethical-legal
2) What are the drivers behind the recent turn of Danish companies towards anti-corruption? 3) In your experience, how did Danish companies respond to the need to develop anti-
corruption?
a. Current status-different sectors.
4) Can you talk to me about the relationship between anti-corruption and CSR? a. Danish context, Chinese context, American context.
5) Can you tell me about private to private and private to public cooperation on anti- corruption?
a. Danish context, abroad.
6) In your experience, how do companies manage anti-corruption abroad and in particular China?
a. Establish departments there? From headquarters? b. Use of law firms and consultancies.
c. Challenges?
7) By what standards CoCs are being designed and drafted? a. Ethical, legal, competitiveness, isomorphism.
8) Can you talk to me about the training of employees on anti-corruption?
a. Ethical, legal, operational, culturally based, in-house or external actors? Ask for a description of the training program. An example maybe?
9) Can you talk to me about performing due diligence on third parties?
a. Ethical, legal, operational, culturally based, in-house or external actors? Ask for a description of due diligence. An example maybe?
10) Question on FCPA and UK Bribery act compared to national legislation. How these two interplay, why companies choose to draft the CoC based on FCPA and Bribery act? How do they see national legislation?
11) Anything else you would like to add?
Round 3:
Question 1: What does corporate compliance/anti-corruption mean for you?
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Question 2: Can you describe to me the organization of your department and your main tasks and responsibilities as a compliance officer?
Grand Question 3: (Interview to the double method-Focus on practice.)
a. Follow up questions when the interviewee starts talking about an activity of interest. For example: You said you check your daily tasks. What tasks are these?
Looking for practical info on activities such as risk assessment, training, due- diligence, code of conduct.
b. Prompting to elaborate on these tasks/activities. Possible prompts:
a. What tools do you use when performing activity X? b. By what standards do you design activity X?
c. Who gets involved in designing/performing activity X? d. What do you aim to accomplish with activity X? e. Why do you think activity X is important?
f. Where do you get inspiration when performing activity X?
g. How do you deal with cultural differences when performing activity X?
h. Given the large size of any MNC, how do you choose who is to be trained/checked/monitored?
Grand question 4: Can you describe to me the role of the compliance department within any company?
Possible prompts:
a. What qualities are necessary for compliance officers to perform their tasks? b. What connections are necessary to fulfill the objective?
c. To whom the department is accountable?
d. What in your opinion is the optimal positioning of the compliance department within a company in order to be effective?
e. What challenges are likely to be faced when performing compliance activities? Question 5: How do you think compliance changes a company internally and externally?
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Possible prompts:
a. Intra-organizationally. What was going on before? b. In relation to governments. What was going on before? c. In relation to other companies. What was going on before?
Question 6 (Cooling off): How do you think corporate compliance/anti-corruption will look like in ten years’ time?
Anything else you would like to add?
Before you go:
a. Any contacts especially in China
b. Any documents to look into (anonymously)
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