CORPORATE POLICY ON BRIBERY PREVENTION 1. OBJECTIVE The Corporate Policy on Bribery Prevention ('Policy') aims to reinforce Itaú Unibanco Conglomerate commitment to. Can the certification of a corruption prevention program be used as a management tool? Céleste Cornu, Anti-Corruption Services Operations Manager.
FCPA Guidance | Anti- Bribery. Be Proactive About Anti Bribery Compliance with FCPA Training.
Building a robust anti-corruption program. effective anti-bribery program in place to prevent an. accurate recordkeeping and prevention of concealment of bribery. Bribery prevention. To ensure respect for a program, whether it be on the part of employees or business partners, external verification is necessary. About FCPA training: defensible FCPA compliance training programs, anti bribery compliance programs & policies. Integrate into the way you operate. 07 The Petrobras Corruption Prevention Program (PCPP)* features continuous actions to prevent, detect and correct acts of fraud and corruption, as set out in this Manual.
The UK Bribery Act 3 Conducting a corruption risk assessment When developing an anti-corruption compliance program, it is important to take the time.
Every day companies learn the hard way that without a comprehensive and consistently enforced anti- bribery program in place, the consequences are devastating. The standards for a defensible program are getting higher every day. Preventing bribery must be integrated into the way you operate, all the time, no exceptions. Whether you have a few employees in one location or thousands scattered around the globe, speaking different languages, experiencing new cultures and encountering different business risks, our anti- bribery solution helps you be compliant with the FCPA. We’ve used the expertise and experience of our 3. Our package includes: Policy Management: part of our Integrated GRC suite, Policy Management gives you a centralized place for employees to reference and attest to policies. We include best practices policy templates for a number of topics, including FCPA.
Training: Access for all employees to our e. Learning course “Global Anti- Bribery: Doing Business Fairly.” This engaging course delivers clear messaging about what constitutes a bribe and how employees can protect themselves and their company against potential bribery issues. Awareness materials: Creative and visually appealing electronic or paper media in a variety of formats that can be posted and distributed to keep anti- bribery efforts top of mind and remind employees what to do if they learn of misconduct. Since even companies with the best anti- bribery programs in the world are not immune from potential issues, it’s critical that you have procedures in place to quickly detect and correct them.
Defensible FCPA Programs. In order to be defensible, your program should be: Understandable: It’s crucial that your training, awareness materials, policies and Code are written in a way that your employees will actually retain and apply when the time comes.
Comprehensive: Simply stating ‘Thou shalt not bribe’ once a year is not enough to be defensible. Refreshed: When the message and visuals never change, employees stop seeing them. Proactive: You must constantly monitor global activities, not just wait for the hotline phones to ring. Localized: For employees to understand the risks and the behavior expected of them, messaging must be in a language and cultural cadence that makes sense to them.