The Care and Maintenance of a State-of-the-Art Anti-Corruption Compliance Program
•
1 like•216 views
Feel free to use my handy guide: (1) to help develop a maintenance plan for your anti-corruption compliance program; (2) as further rationale for allocating corporate resources to your compliance program. Feedback or suggestions? Write me at: rich.young@legalkaizen.com www.legalkaizen.com http://www.legalkaizen.com/continuous-improvement-of-global-anti-corruption-program/
Recommended
Recommended
More Related Content
What's hot
What's hot (14)
Similar to The Care and Maintenance of a State-of-the-Art Anti-Corruption Compliance Program
Similar to The Care and Maintenance of a State-of-the-Art Anti-Corruption Compliance Program (20)
Recently uploaded
Recently uploaded (20)
The Care and Maintenance of a State-of-the-Art Anti-Corruption Compliance Program
- 1. Applicability Filter Importance Filter Urgency FIlter Enforcement proceedings Legislative Conventions Treaties Local Foreign International Administrative & Case Law Political Shifts Evaluate Where: build, buy, transport, warehouse, sell. Who: subsidiaries, suppliers & customers When: Current and planned (M&A activity) Legal Requirements Revise Now? Prevention Detection Discipline Risk Prioritization Number (RPN): Occurrence | Severity | Detection When new requirement takes effect and time required to effect change. Does new requirement necessitate change to compliance program? Document Change Preserve People Process Technology Training Guidance Communication Implement Lessons Learned Hotline Analysis Contractual Best Practices PFMEA Other Requirements “Due Care” Feedback - Industry Groups - Compliance Team - Business Units - Audit | Kaizen Team - Legal Experts - Compliance Team - Subscription Services - Business Units Kaizen Develop Revisions Audit Capture Lessons Learned Global Anti-Corruption Program Continuous Improvement
- 2. Applicability Filter Importance Filter Urgency FIlter Enforcement proceedings Legislative Conventions Treaties Local Foreign International Administrative & Case Law Political Shifts Evaluate Where: build, buy, transport, warehouse, sell. Who: subsidiaries, suppliers & customers When: Current and planned (M&A activity) Legal Requirements Revise Now? Prevention Detection Discipline Risk Prioritization Number (RPN): Occurrence | Severity | Detection When new requirement takes effect and time required to effect change. Does new requirement necessitate change to compliance program? Document Change Preserve People Process Technology Training Guidance Communication Implement Lessons Learned Hotline Analysis Contractual Best Practices PFMEA Other Requirements “Due Care” Feedback - Industry Groups - Compliance Team - Business Units - Audit | Kaizen Team - Legal Experts - Compliance Team - Subscription Services - Business Units Kaizen Develop Revisions Audit Capture Lessons Learned (1) Monitor Potential New Legal Requirements
- 3. Applicability Filter Importance Filter Urgency FIlter Enforcement proceedings Legislative Conventions Treaties Local Foreign International Administrative & Case Law Political Shifts Evaluate Where: build, buy, transport, warehouse, sell. Who: subsidiaries, suppliers & customers When: Current and planned (M&A activity) Legal Requirements Revise Now? Prevention Detection Discipline Risk Prioritization Number (RPN): Occurrence | Severity | Detection When new requirement takes effect and time required to effect change. Does new requirement necessitate change to compliance program? Document Change Preserve People Process Technology Training Guidance Communication Implement Lessons Learned Hotline Analysis Contractual Best Practices PFMEA Other Requirements “Due Care” Feedback - Industry Groups - Compliance Team - Business Units - Audit | Kaizen Team - Legal Experts - Compliance Team - Subscription Services - Business Units Kaizen Develop Revisions Audit Capture Lessons Learned (2) Use Subscription Services, etc.
- 4. Applicability Filter Importance Filter Urgency FIlter Enforcement proceedings Legislative Conventions Treaties Local Foreign International Administrative & Case Law Political Shifts Evaluate Where: build, buy, transport, warehouse, sell. Who: subsidiaries, suppliers & customers When: Current and planned (M&A activity) Legal Requirements Revise Now? Prevention Detection Discipline Risk Prioritization Number (RPN): Occurrence | Severity | Detection When new requirement takes effect and time required to effect change. Does new requirement necessitate change to compliance program? Document Change Preserve People Process Technology Training Guidance Communication Implement Lessons Learned Hotline Analysis Contractual Best Practices PFMEA Other Requirements “Due Care” Feedback - Industry Groups - Compliance Team - Business Units - Audit | Kaizen Team - Legal Experts - Compliance Team - Subscription Services - Business Units Kaizen Develop Revisions Audit Capture Lessons Learned (3) Gather Potential Legal Requirements
- 5. Applicability Filter Importance Filter Urgency FIlter Enforcement proceedings Legislative Conventions Treaties Local Foreign International Administrative & Case Law Political Shifts Evaluate Where: build, buy, transport, warehouse, sell. Who: subsidiaries, suppliers & customers When: Current and planned (M&A activity) Legal Requirements Revise Now? Prevention Detection Discipline Risk Prioritization Number (RPN): Occurrence | Severity | Detection When new requirement takes effect and time required to effect change. Does new requirement necessitate change to compliance program? Document Change Preserve People Process Technology Training Guidance Communication Implement Lessons Learned Hotline Analysis Contractual Best Practices PFMEA Other Requirements “Due Care” Feedback - Industry Groups - Compliance Team - Business Units - Audit | Kaizen Team - Legal Experts - Compliance Team - Subscription Services - Business Units Kaizen Develop Revisions Audit Capture Lessons Learned (4) Filter for Applicability
- 6. Applicability Filter Importance Filter Urgency FIlter Enforcement proceedings Legislative Conventions Treaties Local Foreign International Administrative & Case Law Political Shifts Evaluate Where: build, buy, transport, warehouse, sell. Who: subsidiaries, suppliers & customers When: Current and planned (M&A activity) Legal Requirements Revise Now? Prevention Detection Discipline Risk Prioritization Number (RPN): Occurrence | Severity | Detection When new requirement takes effect and time required to effect change. Does new requirement necessitate change to compliance program? Document Change Preserve People Process Technology Training Guidance Communication Implement Lessons Learned Hotline Analysis Contractual Best Practices PFMEA Other Requirements “Due Care” Feedback - Industry Groups - Compliance Team - Business Units - Audit | Kaizen Team - Legal Experts - Compliance Team - Subscription Services - Business Units Kaizen Develop Revisions Audit Capture Lessons Learned (5) Filter for RPN
- 7. Applicability Filter Importance Filter Urgency FIlter Enforcement proceedings Legislative Conventions Treaties Local Foreign International Administrative & Case Law Political Shifts Evaluate Where: build, buy, transport, warehouse, sell. Who: subsidiaries, suppliers & customers When: Current and planned (M&A activity) Legal Requirements Revise Now? Prevention Detection Discipline Risk Prioritization Number (RPN): Occurrence | Severity | Detection When new requirement takes effect and time required to effect change. All things considered, does new requirement merit change to compliance program? Document Change Preserve People Process Technology Training Guidance Communication Implement Lessons Learned Hotline Analysis Contractual Best Practices PFMEA Other Requirements “Due Care” Feedback - Industry Groups - Compliance Team - Business Units - Audit | Kaizen Team - Legal Experts - Compliance Team - Subscription Services - Business Units Kaizen Develop Revisions Audit Capture Lessons Learned (6) Filter for Urgency
- 8. Applicability Filter Importance Filter Urgency FIlter Enforcement proceedings Legislative Conventions Treaties Local Foreign International Administrative & Case Law Political Shifts Evaluate Where: build, buy, transport, warehouse, sell. Who: subsidiaries, suppliers & customers When: Current and planned (M&A activity) Legal Requirements Revise Now? Prevention Detection Discipline Risk Prioritization Number (RPN): Occurrence | Severity | Detection When new requirement takes effect and time required to effect change. Does new requirement necessitate change to compliance program? Document Change Preserve People Process Technology Training Guidance Communication Implement Lessons Learned Hotline Analysis Contractual Best Practices PFMEA Other Requirements “Due Care” Feedback - Industry Groups - Compliance Team - Business Units - Audit | Kaizen Team - Legal Experts - Compliance Team - Subscription Services - Business Units Kaizen Develop Revisions Audit Capture Lessons Learned (7) Closer Evaluation of Reduced Volume
- 9. Applicability Filter Importance Filter Urgency FIlter Enforcement proceedings Legislative Conventions Treaties Local Foreign International Administrative & Case Law Political Shifts Evaluate Where: build, buy, transport, warehouse, sell. Who: subsidiaries, suppliers & customers When: Current and planned (M&A activity) Legal Requirements Revise Now? Prevention Detection Discipline Risk Prioritization Number (RPN): Occurrence | Severity | Detection When new requirement takes effect and time required to effect change. Does new requirement necessitate change to compliance program? Document Change Preserve People Process Technology Training Guidance Communication Implement Lessons Learned Hotline Analysis Contractual Best Practices PFMEA Other Requirements “Due Care” Feedback - Industry Groups - Compliance Team - Business Units - Audit | Kaizen Team - Legal Experts - Compliance Team - Subscription Services - Business Units Kaizen Develop Revisions Audit Capture Lessons Learned (8) Decide Whether to Revise Program Now
- 10. Applicability Filter Importance Filter Urgency FIlter Enforcement proceedings Legislative Conventions Treaties Local Foreign International Administrative & Case Law Political Shifts Evaluate Where: build, buy, transport, warehouse, sell. Who: subsidiaries, suppliers & customers When: Current and planned (M&A activity) Legal Requirements Revise Now? Prevention Detection Discipline Risk Prioritization Number (RPN): Occurrence | Severity | Detection When new requirement takes effect and time required to effect change. Does new requirement necessitate change to compliance program? Document Change Preserve People Process Technology Training Guidance Communication Implement Lessons Learned Hotline Analysis Contractual Best Practices PFMEA Other Requirements “Due Care” Feedback - Industry Groups - Compliance Team - Business Units - Audit | Kaizen Team - Legal Experts - Compliance Team - Subscription Services - Business Units Kaizen Develop Revisions Audit Capture Lessons Learned (9) If Not Revising Now, Preserve Work
- 11. Applicability Filter Importance Filter Urgency FIlter Enforcement proceedings Legislative Conventions Treaties Local Foreign International Administrative & Case Law Political Shifts Evaluate Where: build, buy, transport, warehouse, sell. Who: subsidiaries, suppliers & customers When: Current and planned (M&A activity) Legal Requirements Revise Now? Prevention Detection Discipline Risk Prioritization Number (RPN): Occurrence | Severity | Detection When new requirement takes effect and time required to effect change. Does new requirement necessitate change to compliance program? Document Change Preserve People Process Technology Training Guidance Communication Implement Lessons Learned Hotline Analysis Contractual Best Practices PFMEA Other Requirements “Due Care” Feedback - Industry Groups - Compliance Team - Business Units - Audit | Kaizen Team - Legal Experts - Compliance Team - Subscription Services - Business Units Kaizen Develop Revisions Audit Capture Lessons Learned (10) Revise Program Per New Requirements
- 12. Applicability Filter Importance Filter Urgency FIlter Enforcement proceedings Legislative Conventions Treaties Local Foreign International Administrative & Case Law Political Shifts Evaluate Where: build, buy, transport, warehouse, sell. Who: subsidiaries, suppliers & customers When: Current and planned (M&A activity) Legal Requirements Revise Now? Prevention Detection Discipline Risk Prioritization Number (RPN): Occurrence | Severity | Detection When new requirement takes effect and time required to effect change. Does new requirement necessitate change to compliance program? Document Change Preserve People Process Technology Training Guidance Communication Implement Lessons Learned Hotline Analysis Contractual Best Practices PFMEA Other Requirements “Due Care” Feedback - Industry Groups - Compliance Team - Business Units - Audit | Kaizen Team - Legal Experts - Compliance Team - Subscription Services - Business Units Kaizen Develop Revisions Audit Capture Lessons Learned (11) Apply to All Phases as Appropriate
- 13. Applicability Filter Importance Filter Urgency FIlter Enforcement proceedings Legislative Conventions Treaties Local Foreign International Administrative & Case Law Political Shifts Evaluate Where: build, buy, transport, warehouse, sell. Who: subsidiaries, suppliers & customers When: Current and planned (M&A activity) Legal Requirements Revise Now? Prevention Detection Discipline Risk Prioritization Number (RPN): Occurrence | Severity | Detection When new requirement takes effect and time required to effect change. Does new requirement necessitate change to compliance program? Document Change Preserve People Process Technology Training Guidance Communication Implement Lessons Learned Hotline Analysis Contractual Best Practices PFMEA Other Requirements “Due Care” Feedback - Industry Groups - Compliance Team - Business Units - Audit | Kaizen Team - Legal Experts - Compliance Team - Subscription Services - Business Units Kaizen Develop Revisions Audit Capture Lessons Learned (12) People 1st, Process 2nd, Technology 3rd
- 14. Applicability Filter Importance Filter Urgency FIlter Enforcement proceedings Legislative Conventions Treaties Local Foreign International Administrative & Case Law Political Shifts Evaluate Where: build, buy, transport, warehouse, sell. Who: subsidiaries, suppliers & customers When: Current and planned (M&A activity) Legal Requirements Revise Now? Prevention Detection Discipline Risk Prioritization Number (RPN): Occurrence | Severity | Detection When new requirement takes effect and time required to effect change. Does new requirement necessitate change to compliance program? Document Change Preserve People Process Technology Training Guidance Communication Implement Lessons Learned Hotline Analysis Contractual Best Practices PFMEA Other Requirements “Due Care” Feedback - Industry Groups - Compliance Team - Business Units - Audit | Kaizen Team - Legal Experts - Compliance Team - Subscription Services - Business Units Kaizen Develop Revisions Audit Capture Lessons Learned (13) Document Revised Process
- 15. Applicability Filter Importance Filter Urgency FIlter Enforcement proceedings Legislative Conventions Treaties Local Foreign International Administrative & Case Law Political Shifts Evaluate Where: build, buy, transport, warehouse, sell. Who: subsidiaries, suppliers & customers When: Current and planned (M&A activity) Legal Requirements Revise Now? Prevention Detection Discipline Risk Prioritization Number (RPN): Occurrence | Severity | Detection When new requirement takes effect and time required to effect change. Does new requirement necessitate change to compliance program? Document Change Preserve People Process Technology Training Guidance Communication Implement Lessons Learned Hotline Analysis Contractual Best Practices PFMEA Other Requirements “Due Care” Feedback - Industry Groups - Compliance Team - Business Units - Audit | Kaizen Team - Legal Experts - Compliance Team - Subscription Services - Business Units Kaizen Develop Revisions Audit Capture Lessons Learned (14) Prepare to Implement Revisions
- 16. Applicability Filter Importance Filter Urgency FIlter Enforcement proceedings Legislative Conventions Treaties Local Foreign International Administrative & Case Law Political Shifts Evaluate Where: build, buy, transport, warehouse, sell. Who: subsidiaries, suppliers & customers When: Current and planned (M&A activity) Legal Requirements Revise Now? Prevention Detection Discipline Risk Prioritization Number (RPN): Occurrence | Severity | Detection When new requirement takes effect and time required to effect change. Does new requirement necessitate change to compliance program? Document Change Preserve People Process Technology Training Guidance Communication Implement Lessons Learned Hotline Analysis Contractual Best Practices PFMEA Other Requirements “Due Care” Feedback - Industry Groups - Compliance Team - Business Units - Audit | Kaizen Team - Legal Experts - Compliance Team - Subscription Services - Business Units Kaizen Develop Revisions Audit Capture Lessons Learned (15) Roll Out Implementation (test market)
- 17. Applicability Filter Importance Filter Urgency FIlter Enforcement proceedings Legislative Conventions Treaties Local Foreign International Administrative & Case Law Political Shifts Evaluate Where: build, buy, transport, warehouse, sell. Who: subsidiaries, suppliers & customers When: Current and planned (M&A activity) Legal Requirements Revise Now? Prevention Detection Discipline Risk Prioritization Number (RPN): Occurrence | Severity | Detection When new requirement takes effect and time required to effect change. Does new requirement necessitate change to compliance program? Document Change Preserve People Process Technology Training Guidance Communication Implement Lessons Learned Hotline Analysis Contractual Best Practices PFMEA Other Requirements “Due Care” Feedback - Industry Groups - Compliance Team - Business Units - Audit | Kaizen Team - Legal Experts - Compliance Team - Subscription Services - Business Units Kaizen Develop Revisions Audit Capture Lessons Learned (16) Conduct Routine & Random Audits
- 18. Applicability Filter Importance Filter Urgency FIlter Enforcement proceedings Legislative Conventions Treaties Local Foreign International Administrative & Case Law Political Shifts Evaluate Where: build, buy, transport, warehouse, sell. Who: subsidiaries, suppliers & customers When: Current and planned (M&A activity) Legal Requirements Revise Now? Prevention Detection Discipline Risk Prioritization Number (RPN): Occurrence | Severity | Detection When new requirement takes effect and time required to effect change. Does new requirement necessitate change to compliance program? Document Change Preserve People Process Technology Training Guidance Communication Implement Lessons Learned Hotline Analysis Contractual Best Practices PFMEA Other Requirements “Due Care” Feedback - Industry Groups - Compliance Team - Business Units - Audit | Kaizen Team - Legal Experts - Compliance Team - Subscription Services - Business Units Kaizen Develop Revisions Audit Capture Lessons Learned (17) Capture Lessons Learned During Audits
- 19. Applicability Filter Importance Filter Urgency FIlter Enforcement proceedings Legislative Conventions Treaties Local Foreign International Administrative & Case Law Political Shifts Evaluate Where: build, buy, transport, warehouse, sell. Who: subsidiaries, suppliers & customers When: Current and planned (M&A activity) Legal Requirements Revise Now? Prevention Detection Discipline Risk Prioritization Number (RPN): Occurrence | Severity | Detection When new requirement takes effect and time required to effect change. Does new requirement necessitate change to compliance program? Document Change Preserve People Process Technology Training Guidance Communication Implement Lessons Learned Hotline Analysis Contractual Best Practices PFMEA Other Requirements “Due Care” Feedback - Industry Groups - Compliance Team - Business Units - Audit | Kaizen Team - Legal Experts - Compliance Team - Subscription Services - Business Units Kaizen Develop Revisions Audit Capture Lessons Learned (18) Make Kaizen Improvements (not policy or program level)
- 20. Applicability Filter Importance Filter Urgency FIlter Enforcement proceedings Legislative Conventions Treaties Local Foreign International Administrative & Case Law Political Shifts Evaluate Where: build, buy, transport, warehouse, sell. Who: subsidiaries, suppliers & customers When: Current and planned (M&A activity) Legal Requirements Revise Now? Prevention Detection Discipline Risk Prioritization Number (RPN): Occurrence | Severity | Detection When new requirement takes effect and time required to effect change. Does new requirement necessitate change to compliance program? Document Change Preserve People Process Technology Training Guidance Communication Implement Lessons Learned Hotline Analysis Contractual Best Practices PFMEA Other Requirements “Due Care” Feedback - Industry Groups - Compliance Team - Business Units - Audit | Kaizen Team - Legal Experts - Compliance Team - Subscription Services - Business Units Kaizen Develop Revisions Audit Capture Lessons Learned (19) Preserve Lessons Learned and Kaizen
- 21. Applicability Filter Importance Filter Urgency FIlter Enforcement proceedings Legislative Conventions Treaties Local Foreign International Administrative & Case Law Political Shifts Evaluate Where: build, buy, transport, warehouse, sell. Who: subsidiaries, suppliers & customers When: Current and planned (M&A activity) Legal Requirements Revise Now? Prevention Detection Discipline Risk Prioritization Number (RPN): Occurrence | Severity | Detection When new requirement takes effect and time required to effect change. Does new requirement necessitate change to compliance program? Document Change Preserve People Process Technology Training Guidance Communication Implement Lessons Learned Hotline Analysis Contractual Best Practices PFMEA Other Requirements “Due Care” Feedback - Industry Groups - Compliance Team - Business Units - Audit | Kaizen Team - Legal Experts - Compliance Team - Subscription Services - Business Units Kaizen Develop Revisions Audit Capture Lessons Learned (20) Add Preserved Know How, “Due Care” to Feedback Loop for Other Requirements
- 22. Applicability Filter Importance Filter Urgency FIlter Enforcement proceedings Legislative Conventions Treaties Local Foreign International Administrative & Case Law Political Shifts Evaluate Where: build, buy, transport, warehouse, sell. Who: subsidiaries, suppliers & customers When: Current and planned (M&A activity) Legal Requirements Revise Now? Prevention Detection Discipline Risk Prioritization Number (RPN): Occurrence | Severity | Detection When new requirement takes effect and time required to effect change. Does new requirement necessitate change to compliance program? Document Change Preserve People Process Technology Training Guidance Communication Implement Lessons Learned Hotline Analysis Contractual Best Practices PFMEA Other Requirements “Due Care” Feedback - Industry Groups - Compliance Team - Business Units - Audit | Kaizen Team - Legal Experts - Compliance Team - Subscription Services - Business Units Kaizen Develop Revisions Audit Capture Lessons Learned (21) Monitor Industry Groups for Other Potential Requirements
- 23. Applicability Filter Importance Filter Urgency FIlter Enforcement proceedings Legislative Conventions Treaties Local Foreign International Administrative & Case Law Political Shifts Evaluate Where: build, buy, transport, warehouse, sell. Who: subsidiaries, suppliers & customers When: Current and planned (M&A activity) Legal Requirements Revise Now? Prevention Detection Discipline Risk Prioritization Number (RPN): Occurrence | Severity | Detection When new requirement takes effect and time required to effect change. Does new requirement necessitate change to compliance program? Document Change Preserve People Process Technology Training Guidance Communication Implement Lessons Learned Hotline Analysis Contractual Best Practices PFMEA Other Requirements “Due Care” Feedback - Industry Groups - Compliance Team - Business Units - Audit | Kaizen Team - Legal Experts - Compliance Team - Subscription Services - Business Units Kaizen Develop Revisions Audit Capture Lessons Learned (22) Gather Other Potential Requirements