Foreign Corrupt Practices Act of 1977 UK Anti-Bribery Act
- 1. Discover why 50,000 professionals have already switched to easy2comply Foreign Corrupt Practices Act of 1977 UK Anti-Bribery Act
- 2. Introduction • In spite of some broad and some minor differences between the FCPA and the UK Bribery Act, there is a wide overlap between the two sets of requirements • Firms can ease the management and review of their obligations using the easy2comply Risk Management software
- 3. Software Focus • The easy2comply software is focused on these areas: 1. Corruption and Bribery Risk Assessment 2. Internal Control Monitoring 3. Policy Dissemination and Sign Off 4. Incident Management 5. Anonymous Whistleblowing • The following slides will take you through each point
- 4. Corruption and Bribery Risk Assessment 4
- 5. Corruption and Bribery Risk Assessment • Create a “map” of your company • Focus on troublesome areas such as: – Third parties – Known countries – Agents • Identify potential risks • Assess risks based on: – Severity / Likelihood – Customised Scorecards
- 6. Business Structure • No limitation to hierarchy • Create easy visual representation of business model • Simple user access model ensuring people can only see / edit what they are allowed to
- 7. Risk Profiling (Scorecards) • Flexible scorecards – build your own question sets, answers and scoring methodology • Ensures consistency and standardisation
- 8. Specific Risk Identification and Assessment • Add your own risks • See risks listed neatly and concisely • Each risk can be explored for a much richer analysis
- 10. Risk Assessment • Impact and Likelihood assessment • Residual Risk based on implemented controls • Different methodologies available
- 11. Benefits of Risk Assessment • Easily identify based on risk assessment where the most problematic areas are • Share Risk Assessments with people from across the company, no matter where they are • Generate charts and Excel reports
- 12. Internal Control Monitoring 12
- 13. Internal Control Monitoring • Build dynamic library of controls • Assign responsibilities for checking the controls • Document evidence on frequent basis • Attach files and documents as part of information gathering process
- 14. Control Libraries • Add your own controls • See who checked them and when • See when they are next due for testing
- 16. Create a Test Plan
- 17. Document Findings and Recommendations
- 18. Upload Attachments as Evidence
- 19. Easy Reporting
- 20. Benefits of Internal Control Monitoring • All data is time-stamped and user-stamped, ensuring full traceability and auditability • People can work in parallel • Evidence uploaded directly into the software • Makes it very easy to demonstrate that there is a proper and formal process to manage controls • Automated notifications and alerts • Simple reporting and charting
- 21. Policy Dissemination and Sign Off 21
- 22. Policy Review
- 23. Track the Policy Team
- 24. Management Signatures • Track who has signed off on the policy in real time • Monitor those that haven’t signed • Creates a digital signature
- 25. Policy Sign Off Benefits • Proof that management have seen and reviewed the policy • Track who has signed and who hasn’t • Include questionnaires (if desired) to ensure the policy is understood
- 26. Incident Management 26
- 27. Incident Management • Identify new and old incidents relating to fraud and corruption • Track the investigation and remediation process • Demonstrate to officials that there was clear ownership and accountability from the moment the issue was identified
- 28. Incident Database • Build database of fraud and corruption related events and incidents • Filter by location, business and date
- 30. Draw Conclusions and Recommendations
- 31. Incident Management Benefits • Anywhere in the world, incidents can be created and entered into the database • Document proof that necessary steps and measures were taken • Build a library of lessons that can be learnt and shared with other business groups
- 32. Anonymous Whistleblowing 32
- 33. Anonymous Whistleblowing • Anyone can record a “potential event” relating to fraud, bribery and corruption • Registrants do not need to log in to a software nor do they need to provide their details • All whistleblowing events will be distributed to a pre-determined group within the company for further analysis
- 34. Where do I record the Event? • Application homepage • No need to log in to the software • Page can be added to client corporate intranet page as well
- 35. What do they fill in? • Fully configurable form • Fields determined by company • Default form can be seen here
- 36. Anonymous Whistleblowing Benefits • Allows all individuals and employees peace of mind when recording incidents • Company can track potential events as they are identified • Prove to regulator that best efforts were made to provide a safe space for the reporting of events
- 37. For more information on the UK Bribery Act or Foreign Corrupt Practices Act, please contact: Jeremy Kaye jeremy.kaye@easy2comply.com Sales sales@easy2comply.com 37