Foreign Corrupt Practices Act of 1977 UK Anti-Bribery Act

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Foreign Corrupt Practices Act of 1977UK Anti-Bribery Act

Introduction

• In spite of some broad and some minor differences between the FCPA and the UK Bribery Act, there is a wide overlap between the two sets of requirements

• Firms can ease the management and review of their obligations using the easy2comply Risk Management software

Software Focus

• The easy2comply software is focused on these areas:

1. Corruption and Bribery Risk Assessment

2. Internal Control Monitoring

3. Policy Dissemination and Sign Off

4. Incident Management

5. Anonymous Whistleblowing

• The following slides will take you through each point

Corruption and Bribery Risk Assessment

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Corruption and Bribery Risk Assessment

• Create a “map” of your company

• Focus on troublesome areas such as:

– Third parties

– Known countries

– Agents

• Identify potential risks

• Assess risks based on:

– Severity / Likelihood

– Customised Scorecards

Business Structure

• No limitation to hierarchy

• Create easy visual representation of business model

• Simple user access model ensuring people can only see / edit what they are allowed to

Risk Profiling (Scorecards)

• Flexible scorecards – build your own question sets, answers and scoring methodology

• Ensures consistency and standardisation

Specific Risk Identification and Assessment

• Add your own risks

• See risks listed neatly and concisely

• Each risk can be explored for a much richer analysis

Clear Risk Documentation

Risk Assessment

• Impact and Likelihood assessment

• Residual Risk based on implemented controls

• Different methodologies available

Benefits of Risk Assessment

• Easily identify based on risk assessment where the most problematic areas are

• Share Risk Assessments with people from across the company, no matter where they are

• Generate charts and Excel reports

Internal Control Monitoring

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Internal Control Monitoring

• Build dynamic library of controls

• Assign responsibilities for checking the controls

• Document evidence on frequent basis

• Attach files and documents as part of information gathering process

Control Libraries

• Add your own controls

• See who checked them and when

• See when they are next due for testing

Control Documentation

Create a Test Plan

Document Findings and Recommendations

Upload Attachments as Evidence

Easy Reporting

Benefits of Internal Control Monitoring

• All data is time-stamped and user-stamped, ensuring full traceability and auditability

• People can work in parallel

• Evidence uploaded directly into the software

• Makes it very easy to demonstrate that there is a proper and formal process to manage controls

• Automated notifications and alerts

• Simple reporting and charting

Policy Dissemination and Sign Off

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Policy Review

Track the Policy Team

Management Signatures

• Track who has signed off on the policy in real time

• Monitor those that haven’t signed

• Creates a digital signature

Policy Sign Off Benefits

• Proof that management have seen and reviewed the policy

• Track who has signed and who hasn’t

• Include questionnaires (if desired) to ensure the policy is understood

Incident Management

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Incident Management

• Identify new and old incidents relating to fraud and corruption

• Track the investigation and remediation process

• Demonstrate to officials that there was clear ownership and accountability from the moment the issue was identified

Incident Database

• Build database of fraud and corruption related events and incidents

• Filter by location, business and date

Document the Incident

Draw Conclusions and Recommendations

Incident Management Benefits

• Anywhere in the world, incidents can be created and entered into the database

• Document proof that necessary steps and measures were taken

• Build a library of lessons that can be learnt and shared with other business groups

Anonymous Whistleblowing

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Anonymous Whistleblowing

• Anyone can record a “potential event” relating to fraud, bribery and corruption

• Registrants do not need to log in to a software nor do they need to provide their details

• All whistleblowing events will be distributed to a pre-determined group within the company for further analysis

Where do I record the Event?

• Application homepage

• No need to log in to the software

• Page can be added to client corporate intranet page as well

What do they fill in?

• Fully configurable form

• Fields determined by company

• Default form can be seen here

Anonymous Whistleblowing Benefits

• Allows all individuals and employees peace of mind when recording incidents

• Company can track potential events as they are identified

• Prove to regulator that best efforts were made to provide a safe space for the reporting of events

For more information on the UK Bribery Act or Foreign Corrupt Practices Act, please contact:

Jeremy Kaye jeremy.kaye@easy2comply.com

Sales sales@easy2comply.com

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