Intelligence Network – an effective instrument for preventive vigilance in PSEs.
Intelligence
Network – an effective instrument for preventive vigilance in PSEs.
Intelligence as an important input for
effective governance has been testified by history. In the modern dimensions of administration
too it has in fact gained in importance though the nature and operation of
intelligence has undergone vast changes keeping with the requirement of the
times.
In the context of vigilance
administration too the role of intelligence cannot be underestimated. While in an enlightened society every
responsible citizen is expected to perform the role of an intelligence
provider, watchfulness by the society is highly limited in respect of
white-collar crimes especially in organizations where transparency has not been
a practice followed in administration.
While a specialized intelligence wing is
part of the organization in respect of investigation agencies like SPE (CBI)
and State Vigilance and anti corruption departments, in respect of regular
Government Department or a PSE by and large no such organized mechanism exists
though some PSEs do have provision for cash incentives for informers. Vigilance
Manual Vol. I para 11 of chapter XVIII confines itself to just a line on the
subject saying, “ CVO should also have a system of collecting his own
intelligence about possible malpractices and misconduct among employees of his
organization.” Govt. Departments generally depend on public complaints or media
reports as the starting point for vigilance investigation. Some PSEs have evolved quite effective but
informal intelligence channels.
Officers
of various enforcement departments like police, income tax, customs etc. do
have the expertise in intelligence work and when posted as CVOs of PSES have
successfully established intelligence networks. However by its very nature, the
details of such a network are not documented and published in literatures for
effective adoption by other enterprises.
This paper hence attempts to make a case
for the need for an intelligence network in a PSE with suggestions for
considerations. The objective of the
paper is to begin a discussion on the need for an intelligence network in a PSE
as an effective instrument in preventive vigilance. The result of the debate/discussion will
bring out the final view of the group in the matter.
PSEs vary widely in their size, nature
of operation. They also vary in terms of
number of units like Cochin Shipyard, which is a single unit enterprise, & NTPC with large number of units all
over the country. The vigilance activity
too hence will be varying accordingly though essentially, the basic nature of
vigilance work may be similar. While
most PSEs have officers from All India and organized central services as CVOs,
they are normally confined to the corporate head quarters. Vigilance activity in units away from the HQ
is carried out by full time or part time VOs/AVOs who are normally employees of
the organization.
Maintaining Continuity
While outsiders when posted as CVOs have
the advantage of looking at the system in an objective and unbiased manner,
they being officers outside the system often fail to comprehend some of the
existing features nexuses and past history that exist in the organization which
may be known to all employees except the CVO who is rank outsider. Though the other officers in the vigilance
set up are generally insiders often many such things are seldom brought to
CVO’s knowledge. To overcome this it is
suggested that CVO may maintain a memorandum book as prescribed in the office
manuals of various central government departments. This Memorandum book, which
is maintained by the head of the office, will give details of various
departments – reports about their defective functioning, allegations etc. Employees and executives about whose conduct
and behavior there are doubts are entered and periodically reviewed. This record maintained in the personal custody is handed over to the new
incumbent during change of incumbency. The important advantage of this is that
it gives a comprehensive view of the organization, sensitive areas, vulnerable
personnel etc. and information gathered over a period a time is available to
new incumbents who would have otherwise not known these.
Sources
of Intelligence:
One of the very useful and cost free
sources of intelligence is the central Industrial Security Force (CISF) an
agency that provides security for most of the PSEs in the country. The CISF
have their own crimes and intelligence wing in each PSE handed by inspectors or
Dy. Commandants, they can provide reliable intelligence especially on
pilferages and officers conniving, procurements and foul plays therein. Regular
meetings (preferably informal) can provide vital information, which can assist
in framing procedures as part of preventive vigilance or apprehending employees
indulging into unfair dealings.
Information center / reception located
normally near the main gate, main building will have useful information about
the various visitors coming to the PSUs along with the officers they are
meeting. Such frequent meeting of
suppliers with certain executives can provide vigilance with some leads to be
associated with cases in hand. In such of those firms where entry passes are
computerized and if the same works in an environment, details of visitors along
with the executives visited.
Govt. of India has laid down guidelines
for inclusion of officers in the agreed list signed with the local branch of
the CBI. While both the vigilance
organization and CBI could keep watch over these persons, another avenue could
be to liaise with the investigation wing of Income Tax department through whom
information pertaining to contractors employed by the PSE could be
gathered. Unduly high expenditures on
hospitality, gifts and other miscellaneous items by the contractors could point
to possible undue benefits enjoyed by some of the persons having dealings with
the contractor, which may possibly include some executives (as envisaged in
para 9, chapter XVIII of Vigilance Manual Volume I).
Regular co-ordination
meeting with CBI as prescribed in the vigilance manual is an appropriate forum
for exchange of intelligence and crossing checking of information. In fact CBI,
the vigilance organization and income tax department can function complimentary
to each other through regular formal and informal meets.
Intelligence
set up within the organization.
A successful intelligence network largely
depends on its silent and unnoticed functioning. An intelligence agent should not be known to
any one in the organization as one, which follows that such personnel will
function without any written or formal orders making them quite anonymous.
Some of the suggestions in this direction
are as follows:
Normally most PSUs have large number of
reemployed ex-service personnel from the armed forces. These employees by virtue or their training
with the defense forces generally have good discipline and more loyalty to the
organization. These employees can form
an excellent network of informers or intelligence agents when properly
motivated to undertake the task. To be
successful, they must keep strict confidentiality of their role, should not
discuss their role with colleagues and friends, generally assigned to report to
one particular officer of the vigilance organization. Interaction between
vigilance and intelligence personnel should be normally done after office hours
preferably outside the office premises.
Intelligence personnel envisaged here are not full time agents but
regular agents but regular employees in various departments as charge man,
rigger, electrician, drivers etc, who in addition to their regular duties keep
the vigilance informed about the various happenings and doubtful activities
going around their place of work.
While a performance based remuneration (or
incentive) to these employees could be considered, it is felt such service
rendered without any monitory remuneration may be more appropriate since the
employee will be doing it purely out of loyalty to the PSU and may not bring to
attention gossips and rumors for the sake of collecting remuneration only.
Quite a bit of information and
intelligence could be gathered though interaction and involvement in the
various community activities like officers club, employees recreation club.
Vigilance personnel hence should not shy away from participation in such social
activities. They need to be good
listeners without showing any apparent keenness for any extra information or
poke the nose in any unrelated conversations.
Informal meeting among the officials of the vigilance department with
the CVO should beheld frequently since some information may come out more
freely in such atmospheres rather than in the formal idol tower set-up.
Cash and bills paid vouchers are normally
maintained in the cash payment section controlled by the accounts department. A
perusal of the various bill paid over a period can throw light on the various
claims like medical, TA, entertainment allowances. Suspicious ones could be
taken up for verification. The constant delay in passing of the bills of few
firms compared to expeditious manners bills of few firms are passed give
indication of possible nexuses between vested interests and few vendors. Detection of ineligible claims by executives
is a common thing in PSUs. They seldom
question any of the claims preferred by top executives. Ineligible claims especially on foreign tours
could be effectively detected. The
knowledge that vigilance is looking into the bills itself will act as a deterrent
preventing many an executive from claiming ineligible benefits.
Based on annual property returns submitted
by the employee, random physical checks could be carried out discreetly to see
if the measurements of buildings value etc. quoted in the returns are
approximately tallying. Local enquiries
from neighbors in suspicious cases can give valuable information about
undisclosed assets owned by the officer / employee.
External Intelligence:-
The system of
informers from outside the organization has been over the years, the main stay
of external intelligence in many an organization. While this is no doubt
important, professional informers who do it for monetary rewards could often
evolve fictious information with the purpose of earning his livelihood. Hence
extreme care is necessary in acting upon the intelligence input received from
such paid sources.
Competitors in the business like
competing suppliers of various materials, contractors, transport operators,
dealers of products manufactured by the PSE could provide vital intelligence
about unfair dealing entered by their rivals in connivance with the personnel
of the PSE. Here again extreme cautionis necessary since business rivalries can
indeed make people to fabricate unsubstantiated charges against rivals and some
of the honest staff of the company.
Another source which probably has not
been exploited and which has good intelligence is from other PSUs, which has
business dealings with the PSU like for eg. Some of the unfair dealings of a
shipping company in repairs could come to the notice of the vigilance
organization of the shipyard where the repair is undertaken. This could be
passed on to the vigilance cell of the customer’s company for further necessary
action.
Likely problems: -
Though the CVC’s circular regarding
special chapter on vigilance in PSU’s suggest that CVOs should function as eyes
and ears of the CEO in a PSU often CVO is looked upon with suspicion because of
the nature of his job and his role and his accessibility to the controlling
ministry or department; his frequent interaction with agencies like CBI etc.
This suspicion is bolstered by the fact that the incumbent is from outside the
organization whose reputation or track record is generally not known to the
staff of the PSU. The functioning of CVO is further hampered by the unique
structure of many PSUs where there is very little delegation of powers and any
irregularity noticed directly or indirectly points the fingers at the CEO. This puts the CVO at an unenviable position.
In this scenario, will the CEOs agree for
an extensive intelligence network? Or is the CVO well within his rights to go
ahead and establish an intelligence system as envisaged in the vigilance manual
(pl. see para 3). The CEOs especially
those who have risen from the ranks in the same organization by virtue of their
acquaintance with large number of employees, executives are bound to have their
loyal group who will be regularly feeding the CEO with vital intelligence (this
may include personnel from the vigilance department also). Often this could be on the activities of
vigilance wing too which could lead to suspicious and mistrust between CVO
& CEO especially when done without informing the CEO.
It hence seems that there is a need to lay
down clear directives empowering CVO to have his own set up for intelligence,
the confidentiality of which need not be disclosed to anyone including the
CEO. This though sounds simple is incongruent
when viewed from the fact that the CVO is a subordinate to the CEO and CVO is
an employee of the company (though he may be an outsider) and controlled by the
CEO. There hence seems to be no simple solution to the dilemma. All the
agencies involved in this task of combating corruption in PSUs need to do
address this and find an appropriate solution taking care of all the above
listed constraints.
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