Foreign Corrupt Practices Act of 1977 UK Anti-Bribery Act


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Foreign Corrupt Practices Act of 1977 UK Anti-Bribery Act

  1. 1. Discover why 50,000 professionals have already switched to easy2complyForeign Corrupt Practices Act of 1977 UK Anti-Bribery Act
  2. 2. 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
  3. 3. 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
  4. 4. Corruption and Bribery Risk Assessment 4
  5. 5. 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
  6. 6. 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
  7. 7. Risk Profiling (Scorecards)• Flexible scorecards – build your own question sets, answers and scoring methodology• Ensures consistency and standardisation
  8. 8. 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
  9. 9. Clear Risk Documentation
  10. 10. Risk Assessment• Impact and Likelihood assessment• Residual Risk based on implemented controls• Different methodologies available
  11. 11. 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
  12. 12. Internal Control Monitoring 12
  13. 13. 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
  14. 14. Control Libraries• Add your own controls• See who checked them and when• See when they are next due for testing
  15. 15. Control Documentation
  16. 16. Create a Test Plan
  17. 17. Document Findings and Recommendations
  18. 18. Upload Attachments as Evidence
  19. 19. Easy Reporting
  20. 20. 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
  21. 21. Policy Dissemination and Sign Off 21
  22. 22. Policy Review
  23. 23. Track the Policy Team
  24. 24. Management Signatures• Track who has signed off on the policy in real time• Monitor those that haven’t signed• Creates a digital signature
  25. 25. 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
  26. 26. Incident Management 26
  27. 27. 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
  28. 28. Incident Database• Build database of fraud and corruption related events and incidents• Filter by location, business and date
  29. 29. Document the Incident
  30. 30. Draw Conclusions and Recommendations
  31. 31. 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
  32. 32. Anonymous Whistleblowing 32
  33. 33. 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
  34. 34. 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
  35. 35. What do they fill in?• Fully configurable form• Fields determined by company• Default form can be seen here
  36. 36. 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
  37. 37. For more information on the UK Bribery Act or ForeignCorrupt Practices Act, please contact:Jeremy Kaye jeremy.kaye@easy2comply.comSales 37