ANTI-BRIBERY HEALTH CHECK

Bribery and corruption is a major issue.  The World Bank has conservatively estimated that around 3% of the Gross World Product is paid in bribes every year, which equates to well over USD$1 trillion dollars.  Eliminating bribery of foreign public officials remains a key priority for the G20 with all countries giving their commitment to enacting and implementing foreign bribery legislation.

Governments have made progress in addressing bribery through international agreements such as the OECD’s convention on combating bribery of foreign public officials, which sets legally binding standards on the 34 OECD member and 7 non-member countries to criminalise bribery of foreign public officials in international business transactions.  The United Nations Convention against Corruption, also sets out a range of general provisions, preventative measures, criminalisation and law enforcement, asset recovery and international co-operation.

The penalties for non-compliance with Anti-Bribery laws are increasing, with the largest fine now nearing USD$1 billion, clearly indicating that many Anti-Bribery programmes are falling way short of what regulators expect of them.

We built the Anti-Bribery Health Check, aligned with the ISO 37001: Anti-Bribery management systems standard which reflects international good practice and is applicable across all jurisdictions, and to small, medium and large organisations in all sectors, and type; including public, private and not-for-profit sectors.

What is the Anti-Bribery Health Check?

The Anti-Bribery Health Check platform is an online platform dedicated to controls assurance and provides a structured framework based on the ISO 37001: anti-bribery management systems, for conducting independent reviews to assess the design and operational effectiveness of anti-bribery programmes.

The Anti-Bribery Health Check platform has been designed to leverage best practices in risk management controls assurance and was built based on a logical hierarchy that links rules and obligations, with policies, risks and controls and provides a means of assessing compliance against obligations, prioritising responses, providing auditor comments and management responses, as well as, assigning actions and attaching documentary evidence to support audit findings.

After the assessment has been completed for each compliance obligation users can create executive summary reports directly from the platform, highlighting the key observations, findings and recommendations, as well as, actions, issues and risks identified during the review process.

The Anti-Bribery Health Check platform also contains rich data analytics that provide actionable business intelligence including; real-time operational dashboards for tracking open and outstanding actions, issues and risks; interactive reports which can slice and dice audit data in many ways including, drilling into particular areas of interest, as well as, benchmarking audit outcomes across different timeframes, divisions and countries, it can even summarise on a single page the compliance status across hundreds of compliance obligations.

Problem Statement

To prevent corruption an organisation needs 5 things:  

Firstly, it needs top management to state a clear commitment to integrity in everything it does.  

Secondly, it needs to have a clear understanding of the bribery and corruption risks that it faces and must develop effective systems, procedures and controls for minimising or mitigating risk exposures

Thirdly, employees, contractors and business associates, particularly those most exposed to corruption risks, must be trained on what to do if they encounter problems or have any concerns.

Next, the organisation must provide effective tools to employees and others to help them to conduct business with integrity, such as registers for recording: conflicts of interest; gifts, hospitality and entertainment; political and charitable donations or tools for managing third party due diligence; audits and training

Finally, organisations need to have a robust framework for regularly monitoring the effectiveness of the anti-bribery and corruption compliance programme to assess whether it is adequate and proportionate; meaning, whether systems, procedures and controls have been designed in a way that are fit for purpose and have been implemented and are operating effectively.

The outputs of the Anti-bribery compliance programme review needs to be provided back to top management and a commitment made for tracking and implementing continual improvement to address any compliance gaps identified.

How we solve it

The Anti-Bribery Health Check Solution has been designed by subject matter experts to provide a structured framework based on the ISO 37001: Anti-bribery management standard for conducting independent audit reviews to rigorously test the design and operational performance of your anti-bribery and corruption compliance programme.

Our solution closely aligns to the ISO 37001: Anti-bribery management standard which was designed to help an organisation implement an anti-bribery management system, by considering hundreds of different measures designed to help organisations to prevent, detect and address bribery.

These measures include; adopting an anti-bribery policy, ensuring commitment by top leadership and appointing an officer accountable for overseeing anti-bribery compliance, training employees, contractors and business associates, undertaking bribery risk assessments and implementing various systems, procedures and controls to support compliance with anti-bribery requirements, as well as, assessing performance and continually improving the anti-bribery and corruption programme in a proportionate and reasonable manner given the nature of the organisation’s activities.

This standard was designed by a global panel of expert practitioners and was designed for use by organisations of all sizes, across the public, private and voluntary sectors, in any country to aid compliance with international good practice and with the relevant anti-bribery legal requirements in all countries in which the organisation operates.

How it works – get started in 4 easy steps

Define the context

The first step in the process is to define the internal and external context in which the Anti-Bribery Health Check is being conducted, which includes providing information under the following sections which provides an insight into the potential level of bribery risks that the organisation might typically face:

  • Operational context
  • Business objectives
  • Stakeholder expectations
  • Anti-bribery mgmt. system scope
  • Context of the risk management process
  • Anti-bribery mgmt. system description
  • Bribery risk assessment
  • Other information.

Conduct Assessment

The second step is to conduct the main assessment which follows a structured approach based on the ISO 37001: Anti-bribery management system standard covering a number of activities:

  • Assess compliance against 200+ requirements
  • Map policies and procedures to requirements
  • Assess the risk materiality of non-compliance
  • Conduct control tests on the design and operational performance of the anti-bribery management system
  • Document the outcomes of the assessment
  • Create actions, issues and risks.

Generate Report(s)

The third step after the assessment has been completed for each anti-bribery measure is for the audit team to create reports directly from the Anti-Bribery Health Check platform.

There is a sophisticated but easy-to-use report writing feature and users can decide what sections of the report are published based on the intended purpose and audience.

All published reports are stored in the Anti-Bribery Health Check Audit History which provides a full audit trail of the completed report and all working notes from the audit, if required.

Reports are automatically indexed and published in several different formats including MS Word and Adobe PDF.

Analyse Outputs

The final step is to analyse the data within the Anti-Bribery Health Check or use the rich data analytics to provide actionable business intelligence including:

  • Real-time operational dashboards for tracking open and outstanding actions, issues and risks
  • Interactive reports which can slice and dice the bribery assessment data in various ways
  • Drilling into particular areas of interest real-time
  • Benchmarking audit outcomes across different timeframes, divisions & countries
  • Summarise on 1 page compliance status across hundreds of different anti-bribery measures.

The Anti-Bribery Health Check also contains a number of additional features including; workflow management of items with automated email notifications; breaches and incident management and dashboards; an in-built anti-bribery program manual authoring tool with in-built expert guidance that will assist your organisation in developing a comprehensive anti-bribery policy and a range of other highly configurable capabilities.

Deployment Options

On-Premise

Our solutions can be installed and run on your organisation’s hardware, behind your own firewall and fully supported by your own organisation’s IT support staff which provides control over how the software is used and maintained and provides peace of mind to organisation’s who may not entrust compliance data hosted outside their premises.

Our IT team can provide support to your organisation’s own IT staff to help get you up and running.

Private Cloud

Our solutions are also available to be deployed off-premise as a ‘software-as-a-service’ (SaaS) offering which can be deployed to any private cloud hosting provider of your choice, for example, Amazon Web Services, IBM Softlayer

Private cloud hosting could provide peace-of-mind that trusted cloud-providers that your organisation may already be using to host other software applications, can be extended to new software applications.

Shared Cloud

Our solutions can also be deployed in the cloud using our preferred cloud-solution provider, Microsoft Azure, which is trusted by 57% of Fortune 500 companies.

Microsoft has the highest standards of security, privacy, transparency and compliance to ensure your data is securely hosted in an in-country data centre, which can dramatically reduce your ongoing support costs in terms of staffing, hardware and software acquisition, ongoing maintenance and power consumption.

In the media

Our subject matter experts are recognised as thought leaders in financial crime prevention and are regularly featured in leading GRC publications showcasing our knowledge and experience. We often present at conferences and have done our share of webinars too!

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