- Creating a compliance policy is essential but it is not enough to satisfy a possible anti-bribery investigation.
- Organizations need to prove that they are following those polices by incorporating compliance into the DNA of their company as a good business practice
- “Tone from the top” is important; “tone from the middle” which actively engages directors, managers and lines of business is as, if not more important
- Effective internal controls ensure your program is working the way it’s designed to – pay attention to those areas of your business which present the highest risk
- Third party relationships;
- Travel gifts and entertainment;
- Sales agents and distributors/commission rates;
- Bartering and free promotional products.
- Use appropriate technology as an integrated component of your compliance program – to ensure consistency, objectivity, audit trail and a single book of record of all anti-bribery activity that is essential for an audit.
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