Anti-Bribery & Anti-Corruption Best Practices to Ensure a Compliant Culture

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1 Anti-Bribery & Anti-Corruption Best Practices to Ensure a Compliant Culture

2 2 Anti-Bribery & Anti-Corruption The far-reaching impact of the UK Bribery Act combined with the aggressive international enforcement of the Foreign Corrupt Practices Act (FCPA) has intensified the need for organizations to ramp up their bribery and corruption risk management strategies. With the promise of increased scrutiny, swifter prosecutions and significant penalties, the need to demonstrate your commitment to eradicating bribery and corruption has never been greater. Starting with an evaluation of your current program, can guide you through this process, enabling you to implement and evidence an anti-bribery program that helps ensure employees and third parties act in accordance with global legislation and your own policies and procedures. We believe an effective approach to anti-corruption includes: Adopting a risk-based approach to bribery & corruption Embedding values that prevent and reject bribery and corruption within a strong Code of Conduct and related written policies Engaging employees and setting the tone for the extended enterprise using functional education and awareness tools Establishing and managing thorough policies for gifts, hospitality and entertainment Undertaking thorough third party due diligence by integrating anti-bribery investigation, policy certification, approval and management Improving and integrating reporting and analytics globally, across your organization Communicating efficiently with staff, third parties and supply chains

3 Anti-Bribery & Anti-Corruption 3 Enhancing the Effectiveness of Your Anti-Corruption Program The UK Bribery Act s stricter requirements raise the bar for anti-bribery programs. Companies that are compliant with the new UK law will generally be compliant under the FCPA and the anti-bribery laws of all OECD countries. As such, in conducting anti-bribery risk assessments, does so through the lens of the UK s adequate procedures threshold. What are adequate procedures, reasonable policies and proper global structures for anti-corruption compliance programs post the UK Bribery Act, FCPA, OECD and US Sentencing Guidelines? It s clear that all employees, third parties, agents and intermediaries conducting business on behalf of an organization worldwide will be covered by new regulations, and that defining and enacting adequate procedures to prevent bribery may be the only admissible defense against prosecution. That said, though, organizations are seeking guidance in defining and enacting adequate procedures. helps organizations address the UK Ministry of Justice s 6 key principles on what constitutes adequate procedures : Principle 1: Risk Assessment Principle 2: Top Level Commitment Principle 3: Due Diligence Principle 4: Clear Practical and Accessible Policies and Procedures Principle 5: Effective Implementation Principle 6: Monitoring and Review

4 4 Anti-Bribery & Anti-Corruption Principle 1: Risk Assessment s in-house attorneys and consultants can help you avoid the mistake of merely ticking the box. We will review your current program, conduct a risk assessment & gap analysis, and develop a bribery risk profile for your organization. Best Practice recommendations: A full understanding of the organization s bribery risk Skilled assessors Consideration of internal and external risk Ongoing review and monitoring offers: Risk assessment methodology & implementation services Delivery of risk exposure profile report and detailed risk mitigation plan Best practice recommendations: Visible senior management commitment Establish a culture of integrity where bribery is never acceptable Ensure policy on bribery is communicated internally and externally Through: A public statement of commitment Personal involvement in Code development and policy communication Appointment of senior manager responsible for ABAC program Principle 2: Top Level Commitment s range of services and resources will enable you to engage senior executives in a manner commensurate with the damage - reputationally, financially and individually - that an anti-bribery violation can cause. offers: Board and executive workshops Internal/external communications Guidance on cultural change Code of Conduct review and development Principle 3: Due Diligence s due diligence tools and services will enable you to identify exactly who you are doing business with and manage the risks posed by your third parties. best practice recommendations: Know who you are doing business with and identify risks relating to: Location Business opportunity Business partners offers: Third party due diligence assessment risk profiling, screening, analysis, case management Review of policies, procedures, business rules and workflow

5 Anti-Bribery & Anti-Corruption 5 best practice recommendations: Policies: Need to be clear, practical, accessible and enforceable Need to take account of the roles of the whole workforce and all entities over which the organization has control Should reflect the findings of the risk assessment May include a Code of Conduct Should cover operational procedures including a speak up provision and case management offers: Code benchmarking and development Policy and procedure consultancy & development Listen Up Hotline and Case Management Incident management training Principle 4: Clear Practical and Accessible Policies and Procedures can help you ensure your anti-bribery and corruption policies and procedures are in line with legislative requirements and meet your unique business risks. Principle 5: Effective Implementation s global leadership in providing, monitoring and evaluating compliance training and education of employees and third parties is unsurpassed and supported by a full-featured learning and communication platform that maximizes your ability to manage and integrate key program components. best practice recommendations: Look at how the policies and procedures will be communicated internally and externally Determine and clarify the nature of training and how it will be rolled out Develop a process for internal reporting of progress to top management Decide upon the extent to which external assurance processes will be engaged Establish the arrangements for monitoring compliance offers: Internal and external education, awareness and communication Policy management, certification and reporting Learning and communication management and reporting Registry best practice recommendations: Institute internal checks and balances to monitor and review policies Elevate the importance of financial monitoring Institutionalize bribery reporting and incident management offers: Ongoing risk assessment services Enterprise GRC platform Registry Listen Up Hotline and Case Management Principle 6: Monitor and Review At we understand that for global organizations, monitoring and reviewing policies and procedures can be challenging but is both worthwhile and necessary. Our combination of advisory and consulting services and supporting tools and technology can help you keep on top of your evolving bribery and corruption risks.

6 6 Anti-Bribery & Anti-Corruption s integrated suite of products and services is built to deliver a solution for your own unique bribery and corruption risks, taking into account your industry, people, culture and geographic profile. And it s all supported by technology components that connect your program elements - enabling you to see the bigger picture. Create and promote a business culture where bribery and corruption is eradicated Because no two organizations are the same, there is no one-size-fits-all solution for any compliance or risk management program. Organizations require a flexible and comprehensive solution partner to help develop, implement and evidence an anticorruption program tailored to meet unique business risks as well as compliance obligations. s anti-bribery solution includes: Risk assessments, policy review and policy development services to ensure your program is watertight Current, innovative and consistently highquality education and awareness tools A state-of-the-art platform to communicate with and train staff and third parties Automated certifications and attestations Questionnaires and surveys to take the pulse of the organization A repository for policies and procedures and a means to communicate them

7 Anti-Bribery & Anti-Corruption 7 Tools to facilitate third party due diligence, including due diligence questionnaires, automated access to external databases to help determine third party risk, case management, workflow tools, and a centralized repository for all information and mitigation history A configurable approval and audit process to supplement your risk management programs in gifts, entertainment and hospitality, anti-bribery, and third party due diligence Real-time reporting and metrics to enhance your communication with employees and third parties The ability to automate risk assessment processes, assignments and results A robust whistleblower hotline and case management solution Skilled advisors who can supplement your internal resources as needed Use s Personal Integrity Barometer to Jumpstart Employee Engagement s free online Personal Integrity Barometer provides an innovative way to focus employees on how they would react in certain situations that could put them at risk of breaching global anti-bribery legislation. Designed to raise awareness of this key business risk in only 2 minutes, the Personal Integrity Barometer helps you: Reinforce anti-corruption policies and procedures Kick-start anti-corruption training or support on-going training Create a buzz in the workplace about the importance of individual responsibility for acting in accordance with anti-corruption legislation - including the UK Bribery Act The Personal Integrity Barometer is delivered online via a unique URL. It s available to organizations at no charge and can be customized with your brand. Contact your sales or services representative for more information on how to deploy it throughout your organization.

8 8 Anti-Bribery & Anti-Corruption Instruction and Communication to Support Your Anti-Bribery & Anti-Corruption Program s instruction and communication titles are used by hundreds of clients and millions of engaged users on 5 continents. We deliver in both video and text & graphics visual formats, in multiple languages and across a wide range of platforms suitable for deployment to both employees and third parties. Here are a few representative titles from our more than 45 title-strong Anti-Bribery & Anti-Corruption library. Change behavior with minute courses (Storytorials, courses, Connections and Perspectives) Anti-Bribery Anti-Corruption Combating Bribery in Business Foreign Corrupt Practices Act (FCPA): Part 1 (Understanding the Law) and Part 2 (Dealing with Third Parties) Global Anti-Bribery: Doing Business with Foreign Public Officials Global Anti-Bribery: Preventing Bribery & Corruption Lobbying and Political Activity Build skills with minute courses (Short Takes, InSights and courses) Foreign Corrupt Bribery Act (FCPA): Bribing a Foreign Official Anti-Corruption Anti-Corruption: Family Fun in Florida The UK Bribery Act: Cover His Expenses The UK Bribery Act: It Could Help Finalize the Deal

9 Anti-Bribery & Anti-Corruption 9 Raise Awareness in short segments of 2-10 minutes (PinPoints, Ethical Moments, SpotLights and Infograms) Anti-Bribery Anti-Bribery: Dealing with Public Officials Anti-Bribery: FCPA/OECD: The Right Guy Anti-Corruption: Getting the Business Anti-Corruption: Government Permits (EU) Anti-Corruption: Making the Deal Happen Bribery by Intermediaries Global Anti-Bribery: UK Bribery Act (office and non-office settings) UK Bribery Act: What Business Partners Should Know UK Bribery Act: What Employees Should Know Specialist Workshops To address the more complex needs of specialist job roles or high-risk functions, SAI Global provides tailored face-to-face workshops developed with input from subject matter experts and leading global anti-bribery and anti-corruption legal practices.

10 USA 101 Morgan Lane Suite 301 Plainsboro NJ T: +1 (877) 470-SAIG [7244] F: Europe 42 The Square Kenilworth Warwickshire, CV8 1EB, UK T: +44 (0) F: +44 (0) Australia 286 Sussex Street Sydney NSW 2000 T: F: info.asiapac@saiglobal.com 51 Sawyer Road Suite 510 Waltham, MA T: F: rd Floor 47 Charles Street London W1J 5EL UK T: +44 (0) F: +44 (0) Normamby Road Southbank VIC 3006 T: F: Richmond Avenue Suite 290 Houston, TX T: F: Building B, Garden Office Park 355 Scarborough Beach Road Osborne Park WA 6017 T: F: About is the industry leader in providing global expertise, perspective, technology and tools that integrate ethics and compliance throughout your organization. For more than twenty-five years, clients have built stronger corporate cultures, enabled good governance and implemented more effective all-around programs with our compliance, risk management and governance solutions. With offices in more than 25 countries and on 4 continents, well over a thousand organizations as clients, and tens of millions of satisfied users, works with clients to integrate a flexible suite of solutions and services specifically tailored for any business or industry. Our solution sets encompass compliance management, risk management, environmental health and safety management, anti-bribery anti-corruption management and Code of Conduct. For more information, please call us at the full service location nearest you or visit Ltd. The name and logo and Ethical Moments and Listen Up names are trademarks of Ltd. ABACBR1102c InSights, PinPoints and SpotLights are registered trademarks of Integrity Interactive, an Company. All Rights Reserved.

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