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Effective Bribery & Corruption Compliance Risk Management

Complying with FCPA and The UK Bribery Act - an 8-Part Podcast Series

This series addresses how GRC professionals can effectively manage bribery and corruption risk.  Each individual podcast focuses on a particular principle of the UK Bribery Act Guidance, but coverage includes FCPA compliance risk management as well as how to effectively manage any compliance risk.

Speakers in this podcast series are Marjorie Doyle, JD, CCEP-F and Jim Slavin, JD, CCEP.

Each topic is self-contained so you can select the topics best for you or the entire series.

Proportionality (Speaker: Jim Slavin; Time: 5 minutes)

An excellent starting point - learn why an organization’s procedures to prevent bribery must be proportionate to the risks it faces. In addition to this being a key element of the UK Bribery Act, Jim discusses how the concept of proportionality aligns with U.S. Federal Sentencing Guidelines and recent deferred prosecution agreements.  Listen to the Proportionality podcast now.

Top Level Commitment: From Senior Management (Speaker: Marjorie Doyle; Time: 4 minutes)

Heighten your awareness about the need for how and why senior management sets the tone for bribery and corruption risk management, why bribery and corruption must be treated differently than other compliance risks, and why it may be necessary to explicitly state the company’s position about when and how to walk away from potential revenue if illicit activity is involved.  Listen to the Top Level Commitment: From Senior Management podcast now.

Top Level Commitment: Communicating a Clear Commitment (Speaker: Marjorie Doyle; Time:  4 minutes)

Marjorie Doyle shines a light on the requirement for both depth and breadth of top level commitment to bribery and corruption risk management and suggests ways to communicate across the organization including both carrot and stick approaches and the need to establish and constantly refer to metrics.  Listen to the Top Level Commtment: Communicating a Clear Commitment  podcast now.

Start at the Beginning: Risk Assessment (Speaker: Jim Slavin; Time: 5 minutes)

Update your knowledge about how risk assessments form the critical first step in complying with proportionality and why risk assessments are a critical step in developing and measuring effectiveness in your entire program.  Listen to the Start at the Beginning: Risk Assessment  podcast now.

The Role of the Risk Assessment in Building Your Plan and Your Program (Speaker: Jim Slavin; Time: 4 minutes)

A great follow-up to the "Start at the Beginning: Risk Assessment" podcast, this podcast focuses on how the results of your risk assessment inform all the steps you’ll take in building a complete anti-bribery program. Jim Slavin pays special attention to how important this could be if and when you face regulatory questions and need to defend that, at the time of alleged wrongdoing, you not only had a plan in place but that the procedures you had in place were considered adequate to prevent bribery.  Listen to the The Role of the Risk Assessment in Building Your Plan and Your Program  podcast now.

Third Party Due Diligence (Speaker: Jim Slavin; Time: 5 minutes)

Explore how a proportionate and risk based approach to bribery and corruption management always includes a plan to manage third parties and inevitably must include a process for due diligence both for onboarding and ongoing management. Jim discusses how an automated approach like SAI Global’s can help organizations manage costs and comply with the spirit and letter of the law. A great follow-up to this podcast would be to see a demo of SAI Global’s due diligence solution.  Listen to the Third Party Due Diligence  podcast now.

Communication (Speaker: Marjorie Doyle; Time: 6 minutes)

What is the extent of an organization's responsibility to ensure that employees and partners understand compliance obligations? Marjorie states the clear need for management to state that bribes are never acceptable regardless of who gains, why it’s important to communicate the parts of the business process that may carry the highest risk, and how to handle situations when they occur.   Listen to the Communication  podcast now.

Auditing and Monitoring (Speaker: Marjorie Doyle; Time: 6 minutes)

The collaboration between Compliance and Internal Audit is critical to effective compliance risk management. Marjorie leads you through the process of identifying the goals of an audit, the type of documentation that is required, and how an audit helps top level management think about compliance as a vital business function rather than as a necessary cost center. Listen to the Auditing and Monitoring  podcast now.


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