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The 12 key confrontations that require your response to update your current Bribery, Fraud and Corruption (BFC) programs, for compliance to new mandates?



The provisions of the U.K. Bribery Act are both wide and broad, compared to the Foreign Corrupt Practices Act (FCPA), which covers bribery of foreign government officials but not private individuals. Penalties for violations also are more severe under the U.K. law and impose unlimited fines against any person or company and imprisonment of up to 10 years.

Therefore you need to custom tailor your current BFC compliance programs to fit the new International mandates.

There are a minimum of 12 questions you should ask about your current Bribery, Fraud and Corruption policies, procedures and controls:

Does your company have the monitoring compliance capacities to:
  1. Have a clear and visible anticorruption, Fraud and Bribery policy with corresponding code of ethics that support each other, function and process.
  2. Ensure that each BRC policy has ownership and are always supported by senior management and communicated throughout the organization?
  3. Are the BFC controls regularly reviewed to make sure they remain effective, adequate and appropriate to the level of BFC risk the company faces?
  4. Guarantee that the lines of BFC defense thru a system of internal controls that are designed to maintain accurate books and records and approvals that prevent their use to facilitate or hide corrupt payments?
  5. Do you have a response plan in place to deal quickly and effectively with incidents of potential corruption?
  6. Do you have a disciplinary process that addresses violations of anticorruption and bribery or fraud procedures?
  7. Do you regularly assess BFC operations to identify potential high-risk areas and ensure the effectiveness of its bribery and anticorruption procedures? Are those efforts proportionate and correspond to the company's BFC risk appetite and exposure?
  8. Do you regularly monitor BFC compliance with bribery and anticorruption procedures by employees, representatives and business partners?
  9. Have you developed mechanism to allow employees, representatives and business partners to report suspicions of BFC activity confidentially?
  10. Are employees, representatives and business partners required to certify regularly that they have read and understood the company's BFC policies and complied with its provisions? Is language relating to the BFC policy included in contracts with third parties?
  11. Are employees and business partners provided with regular training on the anticorruption and bribery procedures?
  12. Is training attendance documented by tests? Is this training tailored to specific work functions, and does it include real-world examples? Are anticorruption procedures and controls included in day-to-day business processes

The above questions are just a fraction of the complete checklist with guidance, templates, training material etc., that the members of The Copenhagen Charter are provided with.