Develop policies to provide practical guidance for all employees on acceptable business practices covering:
• Business ethics – to create a culture of ‘doing the right thing’.
• Conduct and how to deal with conflicts of interest.
• Gifts and hospitality
Ensure that policies are embedded into normal business practices:
• Undertake independent due diligence of all third-party agents and others who are in a position to pay bribes business.
• Ensure that all third-party agents and intermediaries comply with your organisation’s business policies and procedures.
• Review the management of indirect sales channels (eg, agents, advisors, consultants and distributors).
• Include in your terms and conditions of trade the standards of ethical behaviour that you expect of joint venture and other business partners.
• Maintain accurate and timely records of all transactions related to third parties especially in the sales and procurement areas of the organisation.
• Establish mechanisms to enable significant issues to be escalated within the organisation.
• Undertake regular reviews and conduct appropriate audit of relevant business processes to ensure that they remain up to date and corruption risk is identified.
The commitment of staff is crucial to the success of your business policies and processes. To this end:
• Set the ‘tone from the top’ as one of zero tolerance towards bribery, corruption and other related crimes.
• Assign specific responsibilities to the board and senior management. Ensure appropriate oversight and adherence to policies and processes.
• Introduce and maintain a credible mechanism for employees to report concerns.
Ensure that staff and third parties (including customers and suppliers) are fully aware of company policy:
• Communicate clear simple messages across cultures and languages.
• Introduce full disclosure on policy, process and breaches in all reports.
• Ensure disciplinary policy on breaches is communicated and enforced.
• Implement appropriate and ongoing training and education programmes.
Sourced from Fraud Advisory Bureau