Anti-Corruption Compliance in policyIQ: Training review and highlights

*whew*  Another training session under our belts.  I’ll admit – I was nervous about this one.  The topic of Anti-Corruption Compliance is one that fascinates me and I wanted to do it justice.  There are so many different ways that policyIQ might help an organization with the various anti-corruption and anti-bribery compliance initiatives – and we had just one hour to hit the highlights.  (View the recording now!)

While we focused on the United States’ Foreign Corrupt Practices Act (FCPA) and the United Kingdom’s Bribery Act of 2010 (UK Anti-Bribery Act), it’s also important to remember that there are many other anti-corruption laws, local regulations and related legislation that should be considered when building or strengthening your program.

Documentation is key

Through all of my own investigation and learning about the FCPA and the UK Anti-Bribery Act, the key takeaway for me has been that documentation is absolutely critical from start to finish.  Clearn documentation is critical not just of the ultimate expenses that are made (so that you can defend your decisions), but also of the policies, procedures and risk assessments that drive your program.

During the training session, we stressed the need to document a variety of things, such as:

  • Policies and procedures – in detail and with as much context as possible.
  • Your risk assessment, the methodology you used and the support for your decisions around the scope of your anti-corruption programs.
  • Due diligence you conducted on your partners or third parties acting on your behalf, and be sure that they have documented their own internal policies, procedures, etc.
  • Every payment, gift, travel expense or entertainment expense made in a transparent way, so that there can be no question about your motivations or reasons for those expenses.

It was gratifying to hear this point reiterated by one of our attendees, David Roberts, Director at Wall Street Institute, who is responsible for the anti-corruption program in his organization. David followed up in chat to say, “Our organization is constantly reminding of us that.  It is important to note that not only is this important for the company but also the employees.  They are subject to fines and imprisonment.” 

The potential for criminal charges and possible imprisonment should be motivation enough for any employee to get on board with this idea of documentation!

And then you can do this.  And then you can do this.  And then you can…*breathe*

I found myself talking a bit more quickly than normal while presenting the material – both getting excited about the possibilities and anxious about my time limit.  While preparing for the session, we identified eighteen different things that can be organized into or automated by policyIQ, and frankly that was just the eighteen things that fit nicely in our table.  We talked about Anti-Corruption Compliance using the UK’s Ministry of Justice’s guidance on six principles of compliance.  Those six principles are outlined below, along with just a few of the ways that policyIQ might help an organization manage their compliance program.

1.     Risk Assessment

a.   Track Risk Assessments
b.   Report on High Risk Areas

2.     Top Level Commitment

a.   Publish Ethical Conduct Policy internally and externally
b.   Allow all employees and partners to easily reach Corporate Compliance Officer to ask for clarification

3.     Due Diligence

a.   Track all partners and third parties
b.   Retain all Due Diligence documentation

4.     Policies and Procedures

a.   Ask high risk employees and partners to sign off on critical policies
b.   Document specific situational advice and FAQs

5.     Effective Implementation

a.   Use forms in policyIQ to automate Gift Reporting or Expense Request processes
b.   Track Training Attendance

6.     Monitoring and Review

a.   Build and execute audit programs
b.   Periodically review partners and agreements

Great ways to learn more about Anti-Corruption Compliance – specifically FCPA and UK Anti-Bribery

We didn’t go into detail around the specifics of the FCPA or the UK Anti-Bribery Act, and some of you indicated in the evaluation that you were hoping for more information about the legislation.  There are so many nuances and details – and so many far more intelligent folks out there who have great information on the subject.  Here are just a few of the places that I go to get more information:

– Thomas Fox’s FCPA Compliance and Ethics Blog

– Michael Volkov’s Corruption, Crime & Compliance Blog

– If you are on LinkedIn, join the group FCPA – Foreign Corrupt Practices Act – Anti-Corruption Compliance Group

One of our attendees also pointed out that she uses resources from CCH, Deloitte and a variety of other sources found via web searches.  I’ll add Compliance Week to that list, which requires a subscription but is worth it for the wealth of information!

If you have any questions or if you need some help organizing your thoughts to get started, don’t hesitate to reach out to us and we’ll be happy to talk through it!

This entry was posted in Solutions, Training and tagged , , , by Chris Burd. Bookmark the permalink.

About Chris Burd

Chris is the Vice President of the policyIQ group at RGP. She gets geeky about compliance and technology, and gets to spend every day working at the crossroads of the two. With policyIQ since 2005, Chris has worked with hundreds of policyIQ clients to implement technology and enhance their internal compliance environment. In past lives, Chris worked as a system implementation consultant, a e-commerce specialist, a customer service call center manager, and - for one short but memorable summer during high school - a machine operator on midnight shift in a plastics factory. In her free time, she spoils her nieces, reads too many books, and spends more time than she should taking photos of her cats. She's on a mission to visit the hometown of every US President - so far managing to get to 14. She would like to be a rock star when she grows up.

1 thought on “Anti-Corruption Compliance in policyIQ: Training review and highlights

  1. Pingback: Foreign Corrupt Practices Act: Did the Wal-Mart case get your attention? | policyIQ Blog

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