TBC Bank’s Anti-Corruption Vision for a Sustainable Business Environment

How the business sector can contribute to Georgia’s anti-corruption mechanisms; the importance of a cross-sector partnership between the private sector, civil society and the state in developing the country’s anti-corruption policy – these issues are discussed by Natia Mikautadze, Head of Compliance Risk Management at TBC Bank.

Natia Mikautadze, Head of Compliance Risk Management at TBC Bank

Could you tell us about the bank’s anti-corruption activities?

Principle 10 of the UN Global Compact is about combating corruption in all its forms. Let’s take a closer look at this important issue:

Adopted in 2004, Principle 10 of the UN Global Compact calls on companies to actively combat corruption. It’s not just about avoiding corrupt practices; it’s about proactively developing policies and concrete programmes to address corruption both internally within the company and throughout its value and supply chains.

What it means in practice:

• Establishing Clear Policies and Guidelines:
  • Developing and disseminating a code of conduct outlining ethical standards and requirements for compliance.
  • Make policies accessible to all employees
• Leadership Communication: – Consistent communication is essential
  • Senior leaders should regularly communicate their commitment to ethics and compliance through messages, meetings and public statements, emphasizing the importance of ethical behaviour and setting an example.
• Training and Education Programmes:
  •  Providing mandatory training to all employees on ethical standards, compliance policies and reporting mechanisms.
  • Using real-life scenarios and case studies to ensure employees understand how these principles apply in practice.
• Establishing and Promoting Reporting Channels:
  • Setting up multiple, secure and easy-to-use channels for employees to report concerns (e.g. hotlines, online reporting platforms, anonymous whistleblowing systems).
  • Clearly communicating the availability and purpose of these channels so that employees know how to access them and feel confident using them without fear of retaliation.
  • Establishing clear anti-retaliation policies to protect employees who report concerns.
  • Communicating these protections clearly so that employees feel confident about speaking up.
•   Regular Communication Campaigns:

•  Conducting ongoing communication campaigns to remind employees of the organisation’s ethical values, compliance obligations and the importance of speaking up.
• Using newsletters, posters, intranet articles, and workshops to keep the message fresh and relevant.
• Incentives and Recognition:
  •  Publicly recognising and rewarding ethical behaviour to encourage others to act similarly.
  • Making adherence to ethical standards part of employee performance appraisals.
• Regular Reporting and Feedback:
  • Publication of regular reports on compliance efforts and results, such as the UN Global Compact Communication on Progress.
  •  Sharing aggregated, anonymised data on reported concerns and how they have been addressed, demonstrates transparency and commitment to resolving issues.
• Monitoring and Refining Systems:
  • Regular review of the effectiveness of communication and reporting channels.
  • Collecting feedback from employees and stakeholders to identify any barriers to effective communication or gaps in the reporting process, and making adjustments as necessary.
• Creating a continuous feedback loop:

• Holding periodic meetings or surveys to gather employee input on the effectiveness of the ethics and compliance programme.
• Using this feedback to improve communication strategies, reporting systems, and training programs.

In summary, the Bank’s commitment to Principle 10 involves not only avoiding corrupt practices, but also actively working to create a more transparent and ethical business environment. In doing so, it helps to build trust, protect its reputation and promote sustainable practices.

How important is it for the private sector to adopt international standards of business integrity and anti-corruption? Please, tell us more about your internal anti-corruption mechanisms.

To address this question, we need to start with the end goal in mind. For companies, the goal is to build a strong culture of ethics and compliance that not only helps them manage risk more effectively, but also enhances their reputation with stakeholders.

The adoption of international standards of business integrity and anti-corruption by the private sector is not only important but essential for a number of reasons:

First and foremost, this process aims to promote trust and accountability. Fighting corruption and promoting integrity are fundamental to creating an environment of trust and accountability. When companies adhere to high ethical standards, they contribute to a healthier global and local economy.

Furthermore, it has a major impact on the sustainable development of the company, the business community and society as a whole. Corruption is known to be a major threat to the rule of law and sustainable development worldwide. It disproportionately affects vulnerable groups. By adopting ethical practices, complying with anti-corruption laws and demonstrating a commitment to business integrity, the private sector becomes a powerful driver of positive change.

Business integrity and international anti-corruption standards are essential for a transparent, accountable and sustainable global business environment.

Accountability is one of the key components in ensuring transparency. Does TBC Bank produce a corporate sustainability report and is it accessible to all stakeholders?

TBC recognizes the importance of transparency, accountability, and sustainability. Since 2019, we have published annual sustainability reports to communicate our Environmental, Social, and Governance (ESG) efforts to stakeholders. The report, available in both Georgian and English, highlights TBC’s sustainability commitments and provides insights into our activities related to environmental responsibility, social impact, governance practices, and ethical conduct.The reporting process offers valuable insights beyond disclosure; it is also a learning tool—allowing us to benchmark against best practices, measure progress, and identify areas for improvement, fostering a culture of continuous advancement. This approach leads to the establishment of new goals and measurable KPIs, ensuring that ethics and compliance efforts evolve over time rather than stagnating. Additionally, having clear metrics in place enables a company to track its progress and assess how effectively it is integrating ethical practices into daily operations. Regular reporting supports this by showing how well ethics are upheld. Tracking progress against these goals also serves as a motivating factor for employees, who can see that their company is not only committed to ethical standards but is actively improving them.

Overall, TBC’s commitment to transparency is reflected in its sustainability reporting. By openly sharing our ESG efforts, we demonstrate our dedication to responsible banking and a positive impact.

How important is multisectoral partnership between the private sector, the state and the civil sector in the process of developing and implementing the country’s anti-corruption policy?

Multisectoral partnerships – involving organisations from different sectors, including government, the private sector and civil society – are crucial in the process of developing and implementing effective anti-corruption policies. First, it promotes shared responsibility and expertise.

Governments play a central role in policy formulation, legislation, and enforcement, with the authority to create anti-corruption frameworks and regulations. Businesses and corporations contribute practical experience, resources, and innovation, implementing anti-corruption measures within their operations and supply chains. NGOs, community groups, and activists serve as watchdogs, advocating for transparency and accountability. They offer valuable insights and hold both the public and private sectors accountable.

Moreover, by working together, sectors share the risks associated with anti-corruption efforts. No single entity can tackle corruption alone. Combining financial, technical and human resources allows for more effective programmes. For example, civil society organisations can leverage private sector expertise and government funding.

How do you assess the performance of the Georgian business sector in preventing, reducing, and responding to corruption? How can the business sector further promote business integrity and strengthen corruption prevention mechanisms in Georgia?

In recent years, innovation and technology have played a crucial role, with the private sector often leading in technological advancements. As organizations strive to meet their ethical and sustainability commitments, technology enables faster and more accurate reporting of progress.One of the key challenges is the timely collection of accurate and reliable data. Technology—through automation, AI, and data analytics—can streamline this process, ensuring that organizations not only gather the right data but do so efficiently. This allows compliance and ESG teams to focus on interpreting the data and making meaningful progress visible to stakeholders.

AI, in particular, can handle the standardization of routine reports, freeing up time for compliance professionals to focus on more strategic tasks, such as analyzing trends and identifying areas where ethical standards can be strengthened. It also enhances our ability to track historical data, which is essential for demonstrating long-term progress and adherence to ethical commitments. With technology, we can move beyond basic metrics to provide deeper insights that showcase genuine progress in sustainability, human rights, and anti-corruption efforts.

Moreover, the ability to provide real-time updates enables organizations to communicate more effectively and transparently with stakeholders.

With these advances comes the need for ethical considerations. The way data is collected, stored and used must comply with privacy regulations and ensure transparency. As global regulations around data collection and reporting continue to evolve, compliance teams must ensure that technology is used responsibly, with a strong emphasis on ethical practices.

In conclusion, technology is not just a tool for efficiency; it’s an enabler for greater transparency, better decision-making and, ultimately, more ethical business practices. By harnessing these technological advances, organisations can communicate their progress more effectively and provide stakeholders with detailed, meaningful reports that truly reflect their commitment to ethical standards.