Anti-corruption activities and reporting

The purpose of this anti-corruption activity reporting programme is to:

• commit VTT's personnel to fight corruption effectively
• promote the identification of corruption and the transparency of decision-making 
• strive to improve VTT's ability to hold corrupt actors accountable for their actions.

The anti-corruption obligation applies to the entire personnel and management of VTT and its subsidiaries as well as to all VTT's operations. VTT is committed to complying with the United Nations Convention against Corruption (2006/58) as well as national and European Union legislation.

Combating corruption is the responsibility of every VTT employee.

Detection and identification of corruption

Corruption refers to the abuse of influence to gain undue advantage. Influence refers to the ability, power or position that can be used to influence the actions, behaviour, opinions or decision-making of another person.

Corruption often takes the form of giving and taking undue benefits, conflicts of interest, discrimination or favouritism. The benefit may be economic, political or social advantage, and it may accrue to oneself but also to one's sphere of interest.

Not all corruption meets the criteria of a crime. Nevertheless, it always jeopardises the public interest and undermines the transparency, correctness and effectiveness of operations. A culture of non-intervention, where wrong practices are silenced and even defended or protected, enables a corrupt culture to build in the organization. A characteristic feature of the culture of non-interference is that the activities are justified by the principles of expediency and the significance of the activity is downplayed. A course of action that has received tacit approval may become the prevailing way of doing things, in which case intervening in it is not considered good. Persons who have observed corruption also participate passively in misconduct or unethical activities through their non-intervention and secrecy.

Features of corruption include: 

• reciprocity
• loyalty between network actors
• a debt of gratitude due to unjust enrichment.

In order to detect and identify corruption, VTT's most significant corruption risk areas have been analysed as part of VTT's risk management. Possible manifestations of corruption are presented in the table below.

Human resources

• hiring, rewarding or promoting a person on secondary or false grounds
   

Decision-making

• dual roles, interests, conflicts of interest, disqualification
• concealment of decisions
• concentration of decision-making
• deviation from internal guidelines, e.g. on approval limits
• revolving door phenomenon, attempts to influence the transferred person
• external influence: acquiring critical information, creating influence and personal relationships, e.g. infiltrating a person acting for the benefit of an external party into a research project
   

Public procurement

• unlawful direct procurement, unjustified splitting of procurements
• failure to comply with reporting obligations
• tailoring procurement eligibility criteria and evaluation criteria
• unlawful changes to the contract during the contract period
• misuse of confidential information, e.g. price information leakage
• selection of facts in decision-making in order to favour or discriminate against the supplier
• uncontractual or unjustified invoicing
   

Spin-off companies

• dual roles, conflicts of interest, disqualification
   

R&D funding

• researchers' unofficial networks (hyvä veli -verkostot)
• use of funding contrary to financing conditions 
   

Sales

• lubrication money, etc. "custom of the country"
   

Fighting and preventing corruption

VTT's management is strongly committed to anti-corruption by ensuring sufficient resources for raising awareness of corruption, managing corruption risks, investigating suspected corruption and holding perpetrators accountable. VTT combats corruption by ensuring adequate internal operating instructions, organising training and supervising compliance with the guidelines.

The General Counsel is responsible for drawing up organisation-wide guidelines and implementing the anti-corruption programme. The compliance officer and legal and risk management functions guide and advise management, supervisors and personnel in effectively combating corruption. Preventing the formation of a culture of non-interference plays a particularly important role in anti-corruption activities.

The supervisors and personnel of each business unit are responsible for identifying and detecting corruption risks and their manifestations related to their job description and operations, as well as for effectively managing and supervising them. Detected risks shall be reported to management and the internal auditor.

Internal audit objectively assesses the appropriateness and efficiency of the organisation of governance, management and risk management from the perspective of the effectiveness and development of anti-corruption.

Raising awareness of the risk areas and manifestations of corruption complicates corrupt activities and promotes the detection of corruption. Combating corruption is part of VTT's Compliance Programme and related training. Code of Conduct training is mandatory for personnel every two years. In addition, risk-based training targeted at specific target groups is organised annually.

VTT intervenes in suspected corruption and detected corruption consistently, impartially and effectively. Corruption risks are assessed as part of the risk management programme, and the necessary measures are decided annually.

Reports of suspected misconduct should primarily be made to VTT's whistleblower channel. The reporting procedure is instructed in the guidelines "Reporting suspected misconduct and whistleblower protection".

Under certain conditions, the report can also be submitted to the centralised external reporting channel maintained by the Office of the Chancellor of Justice.

Finnish law does not specifically regulate the type of crime defined as a corruption offence. However, corrupt characteristics may be included in criminal offences such as fraud, embezzlement or discrimination. If necessary, VTT will refer suspected misconduct to the police for investigation.

All suspected misconduct, including suspected corruption, is handled in accordance with the instructions on reporting suspected misconduct and whistleblower protection. The Internal Auditor and the Compliance Officer report regularly to the Audit Committee of the Board of Directors.