One of the areas which is universally listed as a component of a best practices compliance policy under the Foreign Corrupt Practices Act (FCPA), UK Bribery Act and OECD Good Practices is that of a written compliance code. However this is not an area that most compliance practitioners spend much time thinking about in the implementation, assessment or updating of their company’s compliance program. This article will discuss some suggestions to aid your efforts to create effective written compliance policies and procedures.
The following language for each of the above laws or policies sets out what is expected in the area of a written compliance policy and procedures:
US Sentencing Guidelines-written standards and procedures to prevent and deter criminal conduct.
UK Bribery Act-clear, practical and assessable written policies and procedures.
OECD-written policy that clearly states that bribery is prohibited.
Recent DPAs (IE, Panalpina Settlements)-clearly articulated and visible policy.
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