An excellent starting point - learn why an organization’s procedures to prevent bribery must be proportionate to the risks it faces. In addition to this being a key element of the UK Bribery Act, Jim discusses how the concept of proportionality aligns with U.S. Federal Sentencing Guidelines and recent deferred prosecution agreements.
Heighten your awareness about the need for how and why senior management sets the tone for bribery and corruption risk management, why bribery and corruption must be treated differently than other compliance risks, and why it may be necessary to explicitly state the company’s position about when and how to walk away from potential revenue if illicit activity is involved.
Marjorie Doyle shines a light on the requirement for both depth and breadth of top level commitment to bribery and corruption risk management and suggests ways to communicate across the organization including both carrot and stick approaches and the need to establish and constantly refer to metrics.
Update your knowledge about how risk assessments form the critical first step in complying with proportionality and why risk assessments are a critical step in developing and measuring effectiveness in your entire program.
A great follow-up to the "Part 4: Risk Assessment - Start at the Beginning" podcast, this podcast focuses on how the results of your risk assessment inform all the steps you’ll take in building a complete anti-bribery program. Jim Slavin pays special attention to how important this could be if and when you face regulatory questions and need to defend that, at the time of alleged wrongdoing, you not only had a plan in place but that the procedures you had in place were considered adequate to prevent bribery.
Explore how a proportionate and risk based approach to bribery and corruption management always includes a plan to manage third parties and inevitably must include a process for due diligence both for onboarding and ongoing management. Jim discusses how an automated approach like SAI Global’s can help organizations manage costs and comply with the spirit and letter of the law. A great follow-up to this podcast would be to see a demo of SAI Global’s due diligence solution.
What is the extent of an organization's responsibility to ensure that employees and partners understand compliance obligations? Marjorie states the clear need for management to state that bribes are never acceptable regardless of who gains, why it’s important to communicate the parts of the business process that may carry the highest risk, and how to handle situations when they occur.
The collaboration between Compliance and Internal Audit is critical to effective compliance risk management. Marjorie leads you through the process of identifying the goals of an audit, the type of documentation that is required, and how an audit helps top level management think about compliance as a vital business function rather than as a necessary cost center.
With foreign and domestic privacy compliance enforcement at an all-time high, thorough privacy and data security measures are imperative to mitigate potential risk and enforcement actions, especially with global companies which may have to comply with different national standards. In order to implement an effective compliance program it is critical to identify accountabilities, clearly communicate corporate policies, and deliver effective training and awareness to all parties involved in an organization, including employees, contractors, and third-party representatives.