What if – and this is a big what if – your company is starting from scratch on its anti-corruption compliance program? Your company’s Code of Conduct includes a paragraph prohibiting foreign bribery and mandating accurate books and records, and says little more. Some companies are able to relate to these questions.
At the outset, your company has to recognize a couple of reality checks – your compliance program will take a year to two years until it is fully implemented. You cannot roll out your entire program with one big announcement, expect buy in or expect the program to be effective.
So, what do you do first? How do you prioritize your effort?
First, you take a deep breath and work within the realities. Second, you have the Board and/or top management authorize and direct the design and implementation of the compliance program. And, of course, you have to secure a commitment to resources. With these assurances in hand, now we get to the fun part.
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