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Key Elements of an Effective Anti-Bribery Management System Implementation

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As the Anti-Bribery is becoming the world's most challenges issues, it is very important for businesses to support their company with the best programs and enhanced protection. The webinar demonstrated that this is possible by implementing ISO 37001 standard, and by identifying the key elements of an effective ISO 37001 implementation.

Main points that have been covered are:
• Definition of ISO 37001
• Case Studies
• Culture, Training and Reinforcement program

Presenter:
Mr. Mohamad Khachab is PECB Partner & Trainer, with 30 years of professional experience in management consultancy, project management, teaching/training, IT Procurement, preparing proposals, information risk management, research, developing bidding documents, and business development activities.

Link of the recorded session published on YouTube: https://youtu.be/wKc-2aHDf5s

Published in: Education
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Key Elements of an Effective Anti-Bribery Management System Implementation

  1. 1. Key Elements of an effective Anti-Bribery Management System ISO 37001 Implementation 1October 13, 2016, Mohamad Khachab, Managing Partner, ICS
  2. 2. Mohamad Khachab PECB Partner and Trainer Mohamad Khachab has 30 years of professional experience in management consultancy, project management, teaching/training, IT Procurement, preparing proposals, information risk management, research, developing bidding documents, and business development activities. Contact Information 703-962-0793 khachabmy@ics4business.com http://www.ics4business.com/ linkedin.com/in/moekhachab
  3. 3. Definition ISO 37001 ISO 37001 is an anti-bribery management system standard designed to help an organization establish, implement, maintain, and improve an anti-bribery compliance program or “management system.” 3October 13, 2016, Mohamad Khachab, Managing Partner, ICS
  4. 4. • Is Bribery still common in the workplace today? Private sector? Public Sector? • Do you have a compliance program? Is it defensible? • Can you demonstrate your compliance to your board? Government (s) ? Regulatory bodies? • How about your agents? • Are you monitoring proactively? How you handle exceptions? • Do you analyze your expenditures? • Can you identify patterns of improper behavior or collusion? • Have you done enough training and education? 4 October 13, 2016, Mohamad Khachab, Managing Partner, ICS
  5. 5. 5 October 13, 2016, Mohamad Khachab, Managing Partner, ICS
  6. 6. Morgan Stanley can serve as a model for any organization to follow as a best practice: • Document everything • Conduct regular program auditing • Educate employees • Implement global financial systems controls 6 October 13, 2016, Mohamad Khachab, Managing Partner, ICS
  7. 7. The Private Sector has a central role to play in preventing detecting and responding to bribery in int’l business. In 2009, the OECD and the Working Group on Bribery released good practice guidance on internal controls, ethics, and compliance. 7 October 13, 2016, Mohamad Khachab, Managing Partner, ICS
  8. 8. 8 October 13, 2016, Mohamad Khachab, Managing Partner, ICS
  9. 9. 9 October 13, 2016, Mohamad Khachab, Managing Partner, ICS
  10. 10. A-B Argentina Australia Austria  Belgium Brazil Bulgaria C-F Canada Chile Colombia Czech Republic Denmark Estonia Finland France G-K Germany Greece Hungary Iceland Ireland Israel Italy Japan Korea L-R Latvia Luxembourg Mexico Netherlands New Zealand Norway Poland Portugal Russia S-Z Slovak Republic Slovenia South Africa Spain Sweden Switzerland Turkey United Kingdom United States http://www.oecd.org/daf/anti-bribery/countryreportsontheimplementationoftheoecdanti-briberyconvention.htm Country reports on the implementation of the OECD Anti-Bribery Convention   Every country that is party to the Anti-bribery Convention has an interest in  ensuring that all parties live up to their obligations. Country monitoring reports  contain recommendations formed from rigorous peer-review examinations of  each country. These country monitoring reports and implementation efforts can  be accessed below. 10 October 13, 2016, Mohamad Khachab, Managing Partner, ICS
  11. 11. Estonia in a Nutshell in 2014 • 29 individuals and 15 entities were sanctioned under criminal proceedings for foreign bribery in 2014. • At least 10 of the sanctioned individuals were sentenced to prison for foreign bribery. • At least 16 individuals and 15 entities (mainly companies) have been sanctioned in criminal, administrative and civil cases for other offences related to foreign bribery, such as money laundering or accounting misconduct, in 8 Parties. • 361 individuals and 126 entities have been sanctioned under criminal proceedings for foreign bribery in 17 Parties between the time the convention entered into force in 1999 and the end of 2014. • At least 95 of the sanctioned individuals were sentenced to prison for foreign bribery. • At least 110 individuals and 200 entities have been sanctioned in criminal, administrative and civil cases for other offences related to foreign bribery, such as money-laundering or accounting, in 8 Parties. • Approximately 393 investigations are ongoing in 25 Parties to the Anti-Bribery Convention. • Prosecutions are ongoing against 142 individuals and 14 entities in 12 Parties for offences under the Convention. 11October 13, 2016, Mohamad Khachab, Managing Partner, ICS
  12. 12. John Verver, CPA, CISA, CMC WWW.acl.com 12 October 13, 2016, Mohamad Khachab, Managing Partner, ICS
  13. 13. 13 October 13, 2016, Mohamad Khachab, Managing Partner, ICS
  14. 14. 14 October 13, 2016, Mohamad Khachab, Managing Partner, ICS
  15. 15. Code of Business Conduct Anti-Bribery Policy Anti-Corruption Toolkit Risk Mapping Risk Assessment Partnerships CULTURE Reporting & Documentation Globalization Education & Training ISO 37001 Monitoring & Testing Commitment Resources / Know-How Control Environment Ethics Internal Audit 15 October 13, 2016, Mohamad Khachab, Managing Partner, ICS
  16. 16. You need to implement a plan Earn/Guarantee senior level support for your plan,  budget, needed dedicated resources. Keep them informed. PMO to manage the project, documents, and  deliverables. Increase awareness within organization and with  stakeholders. 16 October 13, 2016, Mohamad Khachab, Managing Partner, ICS
  17. 17. Culture • Be diligent in your efforts to promote an ethical culture and ensure that people work within the confines of the rules. • People go to work with a core function; are hired to do a job. • People face dilemmas on jobs, and are supposed to make decisions. 17 October 13, 2016, Mohamad Khachab, Managing Partner, ICS
  18. 18. Ethics Office • Every government agency or private organization should have an ethics office and every ethics office shall be staffed with ethics officials. • These individuals shall be available every day to answer questions related to standards of conduct in a confidential secure fashion. 18 October 13, 2016, Mohamad Khachab, Managing Partner, ICS
  19. 19. Training • Increased need reported. • Annual training must be given to all employees who hold positions of significant responsibility or authority. • Annual required verbal training for public filers each calendar year. • Agencies are encouraged to vary the content of verbal training from year to year but the training must include, at least, a review of the following items: 19 October 13, 2016, Mohamad Khachab, Managing Partner, ICS
  20. 20. Training - 2 (1) General principles for ethical conduct (2) The Standards of conduct (3) Any supplemental standards; (4) Conflict of interest statutes; and (5) Contact information of persons / advisors on ethics issues. Employees must be given at least one hour of official duty time for verbal training. 20 October 13, 2016, Mohamad Khachab, Managing Partner, ICS
  21. 21. Training - 3 The training must be: (1) Presented by a qualified instructor; or (2) Prepared by a qualified instructor and presented either in-class, web-based, or thru videotape. • If the training is prepared by a qualified instructor and presented in non-classroom setting, a qualified instructor must be available during and immediately after the training to answer questions. 21 October 13, 2016, Mohamad Khachab, Managing Partner, ICS
  22. 22. Education • Education is foundation of any ethics program. It must be visible, consistent, and flexible. • Assess the education needs of your ethics officials by administering an annual training needs assessment questionnaire and collecting post-training evaluation data. • Training must be the central part of your ethics program 22 October 13, 2016, Mohamad Khachab, Managing Partner, ICS
  23. 23. Customization Customization of education and training allow employees to learn in the context of their agency or job and this is important to ensure that people actually process the information given to them and feel equipped to deal with challenges as they arise. 23 October 13, 2016, Mohamad Khachab, Managing Partner, ICS
  24. 24. Awards / Reinforcement Program • Develop an awards program to allow your organization to use positive reinforcement to encourage offices/branches to focus on education. 24 October 13, 2016, Mohamad Khachab, Managing Partner, ICS
  25. 25. MEDIA • Use media intelligently. • Send a strong message. • Use posters to send message. Post them strategically. They are quick and very economic to produce and can be customized to treat specific issues at specific locations. 25 October 13, 2016, Mohamad Khachab, Managing Partner, ICS
  26. 26. Technology The days where auditing a selected sample of few transactions is long gone. Today regulators require organizations to install comprehensive monitoring tools to mitigate risk especially for those organizations that work in multi-international/national environments. Awareness raising activities highlight the benefits of compliance, including potentially saving the company from both the risk of bribery and the costs Involved in exposure and sanctioning. Today’s boards have to be aware of environment, standards, new trends, technological factors, and risk(s). 26 October 13, 2016, Mohamad Khachab, Managing Partner, ICS
  27. 27. 27 October 13, 2016, Mohamad Khachab, Managing Partner, ICS
  28. 28. 28 October 13, 2016, Mohamad Khachab, Managing Partner, ICS
  29. 29. Welcome to EthicsLine EthicsLine is a reporting service offered by The Coca-Cola Company and administered by a third party, Global Compliance. •You may access EthicsLine by telephone or on this website.Telephone Call toll free at 1(866)790-5579 in the United States and Canada, or go to the list of toll free international access codes. •Online To get started, we need some basic information from you. 1. Where are you located? 2. Where did the event you are contacting us about take place? Click "continue" to proceed. Continue Issues Concerning Immediate Violence or Threat Contact the Strategic Security KO Operations Center in the U.S. at (404)676-6931 or toll free at 1(800)515-2022. Email: koc@coca-cola.com 29 October 13, 2016, Mohamad Khachab, Managing Partner, ICS
  30. 30. THANK YOU ? 703-962-0793 khachabmy@ics4business.com http://www.ics4business.com/ linkedin.com/in/moekhachab

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