As part of my continuing series on building an anti-corruption compliance program from scratch, we need to work on the next step in our continuing series. In yesterday’s post I described the risk assessment process. So, your Bible is now complete.
Your risk assessment outlines potential risks and covers the following: geographic areas of operation and levels of corruption in these countries; industry corruption levels and enforcement actions; foreign government interactions: sales, regulatory and audit or inspections; use of third party agents, intermediaries and/or distributors; existing policies and procedures for gifts, meals, entertainment and travel; existence of joint ventures and policies and procedures for due diligence for joint ventures and mergers and acquisitions; response to foreign government tenders; interactions with suppliers and procurement officers; and charitable contributions.
With these risks as your guideposts, you now need to take stock of the organization and internal controls used within the company. How do your company’s systems interact? For example, are all of your offices and regions interconnected electronically so that documents can be shared, transmitted and the work flow process can be monitored for approvals and payments? How are contracts approved? How are payments approved? These areas have to be mapped out and they become the skeleton upon which the anti-corruption program can be crafted.
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