Presentation by Anatoly Kilyachkov (Manager, auditing services, Ernst & Young) on topic: “Criteria for verification of anticorruption compliance programs”. International Compliance Conference on the Level of Implementation During and After The Sanctions, October 27th

1. Subtitle (Arial regular 20 point)
XX Month 200X (Arial regular 16 point)
Criteria for verification of anticorruption
compliance programs
Anatoly Kilyachkov
manager, FIDS
EY – Moscow
27 October 2014

2. Страница 2
Principles
Criteria for verification of anticorruption compliance programs should be based on the following principles:
–Continuity. Criteria should be based on ‘Anticorruption Guidance’ (appr. by Ministry of Labor and social protection, 08.11.13).
–Consistency. Criteria should assess all kinds of anticorruption activities in a company. They should rely upon corresponding adjustments in the legislation.
–Usability. Criteria should be easy-to-use with their characteristics observed and measurable.
–Adaptability. Criteria should be applicable for verification of anticorruption compliance programs of small and medium enterprises with minimum modifications.
–Adequacy. The assessment of anticorruption compliance program implemented in a company should be objective and not to demand unreasonably high expenses for fulfilling them.

3. Страница 3
Consistency
Criteria should enable to check the implementation of all major kinds of anticorruption activities in a company:
–Regulatory, meaning that a company should have a required set of internal Anticorruption Standards complying with the Russian legislation.
–Executing, implying fulfillment of all required anticorruption activities and their effectiveness.
–Control, enabling to monitor anticorruption procedures implemented in a company along with quality control.
–Information, implying large public awareness of active anticorruption activities in a company and results with training program for all types of managers and employees. Legislation, in turn, should contain leniency provision for receiving illegal gratification on behalf of a legal entity for companies which have implemented anticorruption procedures (art.19.28 The Code of the Russian Federation on Administrative Offenses).

4. Страница 4
Usability (examples)
Kind of activity
Criterion
Evidence
Regulatory
Completeness and quality of legislative environment
1. Management’s clear and public announcement of its readiness to comply with anticorruption requirements.
2. A set of internal anticorruption standards that have been developed, approved and subject to execution in a company.
3. Internal standards contain anticorruption requirements.
Executing
Functions of anticorruption procedures implemented in a company comply with their standard content.
Top management of a company:
1) hears a report on fulfillment of anticorruption activities at every meeting.
2) is aware of its obligations of compliance with the anticorruption policy.
3) is aware of the anticorruption legislation in the countries where a company runs business.
Information
System of anticorruption training and retraining for management and employees.
1.Introductory trainings.
2.Regular (annual) trainings.
3.Special trainings.
4.Additional trainings etc.

5. Страница 5
Adaptability (cost vs quality)
Effective anticorruption activities that are in compliance with current anticorruption requirements.
Activities that can be implemented with minimum costs of their realization
The methodology should suggest the following actions for small and medium enterprises:

6. Страница 6
Adaptability (results)
Transparency International described:
► 231 anticorruption actions for
► 26 processes.
Taking into account SME specific we get:
► 29 anticorruption actions for
► 8 processes.
Filter cost vs quality gives:
► 95 anticorruption actions for
►10 processes.

7. Страница 7
Adequacy
Size
Characteristics of criterion factor
Criterion value
Large enterprises
B – basic
R – recommended
O – optional
Perfect
Good
Satisfactory
Bad
Very bad
Small and medium enterprises
Only basic
Satisfactory
Unsatisfactory

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