Managing Conflict of Interest - Organisation for Economic Co ...

176 Managing Conflict of InterestBayer’s policies extend to internal transactions and activities,as well as external transactions involving the public sector. No personalfavor of any kind shall be offered or rendered to any domesticor foreign public official. This prohibition applies to any kind of giftor other incentive except for customary token gifts that are of nominalintrinsic value.Focusing on Training and Developing a Culture of ComplianceBayer’s policies and expectations regarding behavior are communicatedto staff through ongoing personal face-to-face training,which takes an international approach and includes ongoingdialogue or “permanent discussion” throughout all levels of thecompany.Training efforts reiterate the connection between business successor sustainability and compliance with good governance policies,sending a clear and simple message: forgo business or anyactivity associated with noncompliance with these policies. Theconnection between performance measurement and compliance isalso communicated to top-level managers. As actions may speaklouder than words, managers are held responsible for eventualcases of noncompliance in their area of responsibility.Bayer’s approach to enforcement is just as comprehensive andrigorous, and involves dedicated staff, investigational power, uniformstandards, and a global compliance network. At the sametime, Bayer makes an effort to simplify information and proceduresin handling assumed cases of noncompliance and provides a globalhotline for easy and confidential reporting in multiple languages.ADB/OECD Anti-Corruption Initiative for Asia and the Pacific