FCPA 10 Hallmarks Self- Assessment
|
|
- Domenic Wilkerson
- 8 years ago
- Views:
Transcription
1 FCPA 10 Hallmarks Self- Assessment How exposed is your business to corruption risk? Take this assessment to find out if your systems are sufficiently robust to protect your business October 2014 Prepared by Compliance Experts
2 FCPA VULNERABILITY ASSESSMENT REF QUESTION YES NO N/A COMMENT 1. Commitment from Senior Management and a Clearly Articulated Policy Against Corruption 1.01 Has the organization documented a clear and concise anti-corruption compliance policy? 1.02 Does the policy take into account the nature of the business, having regard to: a) Products b) Services c) Locations d) Operations e) Transactions 1.03 Does the policy indicate a commitment to continual improvement in anti-corruption compliance, and prevention of corrupt transactions? 1.04 Does the policy commit the organization to comply with the FCPA and other anti-corruption laws in all areas in which it operates? 1.05 Does the policy commit to and provide an overall framework for setting improvement objectives and targets by specifying broad organizational goals? 1.06 Does the policy mandate the commitment of every person in the organization to comply with its requirements? 1.07 Has the organization's anti-corruption policy been authorized by top management? 1.08 Has the policy been communicated to all employees and all business functions? 1.09 Has the policy been communicated to all business partners with whom the organization deals, including: a) Customers b) Third party agents c) Contractors/sub contractors d) Government officials 1.10 Is the policy available to interested parties? 1.11 Is the policy available in the local languages for all countries in which the organization operates? 2. Code of Conduct and Compliance Policies and Procedures 2.01 Is there a documented process for identifying and accessing legal and other requirements relating to corrupt practices associated with your business?
3 Are these legal and other requirements taken into account in establishing, implementing and maintaining the compliance system? Is this information kept up to date? Is there a mechanism for effectively communicating relevant information on legal and other requirements such as regulations, standards, codes of practice, agreements and guidelines to persons working under the control of the organization and other relevant parties? Are anti-corruption objectives established, implemented, and maintained at each relevant function and level? Are objectives measurable, where practicable? Do objectives include a specific commitment to: a) Comply with applicable legal requirements b) Continual improvement? Are the following key factors taken into account when objectives are established and reviewed? a) Legal and other requirements b) Corruption Risks c) Technological options d) Financial options e) Operational issues f) Business requirements g) Views of relevant interested parties Do international contracts contain the following FCPA related clauses? a) Requiring the parties to know and comply with FCPA requirements. b) Requiring the provision of documents and records in the event of an Investigation. c) Providing for the cancellation of the contract in the event of an FCPA violation. Have program(s) for the achievement of anticorruption objectives been established, implemented and maintained? Have procedures been established, implemented and maintained for the ongoing prevention of corrupt practices? Do such procedures contain adequate definitions to ensure compliance - including the following? a) Responsibilities b) Proper internal controls c) Auditing practices d) Records e) Documentation requirements 2.13 Do such procedures cover the full scope of the organization's activities and operations, including the
4 following? a) Products and services b) Third-party agents c) Customers d) Government interactions e) Industry related risks f) Geographic risks Do such procedures adequately address all FCPA related risks facing the organization, including the following? a) The nature and extent of transactions with foreign governments b) Payments to foreign officials c) Use of third parties d) Gifts e) Travel f) Entertainment expenses g) Charitable and political donations h) Facilitating and expediting payments Do such procedures detail appropriate transaction approval mechanisms including the specification of the following? a) Monetary transaction limits b) Annual transaction limits c) Routing of unusual requests to senior management Has the organization designed and implemented a robust system of internal accounting controls to ensure that transactions are executed only in accordance with management s general or specific authorization? Does the system of internal accounting controls adequately take into account the operational realities and risks attendant to the organization - including the following? a) The nature of its products and services b) How the products or services get to market c) The nature of its work force d) The degree of regulation e) The extent of interactions with government(s) f) The degree to which the organization has operations in countries with a high risk of corruption Do procedures include the requirement to make and keep books, records, and accounts, which, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the organization? Do procedures include the requirement to record transactions in such a way as to permit preparation of financial statements in conformity with generally accepted accounting principles or any other criteria applicable to such statements?
5 2.20 Do procedures include the requirement to maintain accountability for assets? Do procedures permit access to assets only in accordance with management s general or specific authorization? Do procedures ensure that the recorded accountability for assets is compared with the existing assets at reasonable intervals and appropriate action is taken with respect to any differences? Do procedures specify controls to prevent the misreporting of these types of payment? a) Commissions or Royalties b) Consulting Fees c) Sales and Marketing Expenses d) Scientific Incentives or Studies e) Travel and Entertainment Expenses f) Rebates or Discounts g) After Sales Service Fees h) Miscellaneous Expenses i) Petty Cash Withdrawals j) Free Goods k) Intercompany Accounts l) Supplier / Vendor Payments m) Write-offs n) 'Customs Intervention' Payments Does the organization have a class of securities registered pursuant to Section 12 of the Exchange Act or that is required to file annual or other periodic reports pursuant to Section 15(d) of the Exchange Act.? Has the organization complied with SOX Section 404 (15 U.S.C. 7262) (Reporting on the State of a Company s Internal Controls over Financial Reporting)? Has the organization complied with SOX Section 802 (18 U.S.C and 1520) (Criminal Penalties for Altering Documents)? Has the organization complied with SOX Section 302 (15 U.S.C. 7241) (Responsibility of Corporate Officers for the Accuracy and Validity of Corporate Financial Reports)? 3. Oversight, Autonomy, and Resources 3.01 Has the organization assigned responsibility for the oversight and implementation of the anti-corruption compliance policy to one or more specific senior executives? 3.02 Are such senior executives able to operate autonomously in the performance of their duties?
6 3.03 Do such senior executives have access to the organization s governing authority? 3.04 Has the organization defined roles, allocated responsibilities and accountabilities, and delegated authorities at all business levels to facilitate effective implementation of the compliance program? 3.05 Have roles, responsibilities, accountabilities, and authorities been documented and communicated to all persons working in the organization? 3.06 Has the organization allocated adequate staffing and resources relative to the size, structure, and risk profile of the business? 4. Risk Assessment Has a procedure been established, implemented and maintained for the ongoing identification and assessment of FCPA violation risks? Is the methodology for risk assessment defined with respect to its scope, nature and timing to ensure it is proactive? Does the procedure require a focus on high-risk markets, activities and transactions rather than lowrisk areas? Does the procedure address all types of activities and transactions, including the following? a) Routine activities and transactions b) Non routine activities and transactions c) Large government bids d) Questionable payments to third-party consultants Does the procedure ensure that the risk assessment approach is commensurate with the size and risk of the transaction? Does the procedure include the determination of appropriate control measures relative to the identified risk, such as increased due diligence, monitoring, or periodical audits? Are control measures appropriate given the exposure of the organization to key risks including the following? a) Country b) Industry sector c) The business opportunity d) Potential business partners e) Level of involvement with governments f) Amount of government regulation and oversight g) Exposure to customs and immigration in conducting business affairs Does the procedure take into account risks
7 4.09 associated with proposed changes in the organization, its activities, products and services, or the markets in which it operates? Following implementation of the risk management program, can it be said that the organization fully understands the risks associated with foreign corrupt practices (bribery), and has implemented robust controls to mitigate these risks? 5. Training and Continuing Advice 5.01 Is there a procedure in place for identifying competency needs of the following internal and external stakeholders with whom it deals? a) Top management b) Employees c) Customers d) Third party agents e) Contractors/sub contractors f) Government officials 5.02 Does the organization operate an anti-corruption training program? 5.03 Does the training program cover these key topics? a) Identification and management of corruption risks b) Related company policies and procedures c) Instruction on laws relating to the countries and industries in which the organization operates d) Practical advice to address real-life scenarios e) Case studies 5.04 Is the training presented in a manner appropriate for the targeted audience? 5.05 Is the training and training materials provided in the local language? Is the training supplemented by guidance and advice on complying with the company s ethics and compliance program? Does this procedure take into account differing levels of responsibility, ability, language skills, literacy and risk? 5.08 Are training records retained for all training provided? 5.09 Does the organization evaluate the effectiveness of the training or action taken, and retain associated records? 6. Incentives and Disciplinary Measures
8 Does the organization provide positive incentives such as these? a) Personnel evaluations and promotions b) Rewards for improving and developing the company s compliance program c) Rewards for ethics and compliance leadership Is adherence to compliance a significant metric for management s bonuses so that compliance becomes an integral part of management s everyday concern? 6.03 Are compliance professionals and internal audit staff recognized by the organization? 6.04 Has the organization implemented appropriate and clear disciplinary procedures? 6.05 Have these procedures been applied consistently and promptly? 6.06 Are disciplinary procedures commensurate with the related violation? 7.Third Party Due Diligence and Payments Has the organization clearly identified all third parties assisting the organization in some aspect of its foreign business? Have adequate procedures been established, implemented and maintained for the conduct of due diligence on third parties? Do such procedures provide for due diligence on the following related third parties? a) Agents b) Consultants c) Distributors Do such procedures require the ongoing assessment of third parties in relation to their qualifications, associations, and relationships with foreign officials, and the person(s) in the organization who have authority to enter into a contract with them? 7.05 Do such procedures require an increased level of scrutiny where "red flags" surface? 7.06 Do such procedures require the detailed analysis of the business rationale behind the third party engagement, including these key factors? a) Including the third party in the transaction b) The role of and the need for the third party c) The contract terms specifying the services to be performed d) The timing of the introduction of the
9 third party to the transaction Do such procedures require the analysis of the following financial components of each third party transaction? a) Payment terms b) Timing of payments c) Comparison with other similar transactions in the industry or country concerned Do such procedures require verification that the third party is actually performing the specified work and that payments are commensurate with this work? Do such procedures include a system for ongoing monitoring of third party relationships using these mechanisms? a) Updating due diligence periodically b) Exercising audit rights c) Providing periodic training d) Requesting annual compliance certifications by the third party 7.10 Has the organization informed third parties of its compliance program and commitment to ethical and lawful business practices or where appropriate, sought assurances from third parties, through certifications and otherwise, of reciprocal commitments? 8. Confidential Reporting and Internal Investigation Does the organization have a mechanism for an organization s employees and others to report suspected or actual misconduct or violations of its policies? Are all reports treated on a confidential basis? 8.03 Does the mechanism ensure that employees and others are able to report without fear of retaliation? 8.04 Does the organization have an efficient, reliable, and properly funded process for investigating the allegation and documenting the organization s response? 8.05 Do policies and procedures include disciplinary or remediation measures to be taken? 8.06 Does the company analyze reported violations and the outcome of any resulting investigations in order to update its internal controls and compliance program and focus future training on such issues, as appropriate? 9. Continuous Improvement: Periodic Testing and Review 9.01 Does top management review the compliance
10 program at planned intervals, to ensure that it remains current, relevant and appropriate to the organization? Are the anti-corruption policy objectives and performance measured against stated objectives and targets? Do such steps include a review of ongoing changes such as these? a) The company s business over time b) The environments in which the company operates c) The nature of its customers d) The laws that govern its actions e) Industry standards Do reviews cover audit findings? 9.05 Is the compliance program updated following management reviews? 9.06 Are the outputs from management reviews consistent with the organization's commitment to continual improvement? 9.07 Are relevant outputs from management reviews made available for communication and consultation? 9.08 Are top management reviews documented and retained? 9.09 Do documented procedures detail the process to monitor and measure performance of the compliance program on a regular basis? 9.10 Do the procedures require the implementation of these performance measurement activities? a) Qualitative measures for the needs of the organization b) Quantitative measures for the needs of the organization c) Monitoring the extent of meeting FCPA objectives d) Use of proactive measures of performance e) Use of reactive measures of performance to monitor incidents and adverse events f) Recording of results and date of monitoring and measurement 9.11 Does the organization undertake a critical evaluation of its potential weaknesses and risk areas, such as surveys to measure compliance culture and the strength of internal controls, identify best practices, and detect new risk areas? 9.12 Does the organization undertake targeted audits to make certain that controls on paper are working in
11 practice? Are audit programs and schedules based on corruption risks and significant aspects of business operations, locations, and processes? Does the selection of auditors and conduct of audits ensure objectivity and the impartiality of the audit process? Do the audits seek to determine these key objectives? a) Conformance of the Compliance Program to FCPA regulations and other applicable regulations b) That the Compliance Program has been properly implemented and maintained c) That the Compliance Program is effective in meeting the organization's policy and objectives Do the audits review the results of previous audits? 9.17 Are audit results communicated to and reviewed by top management? 9.18 Are audit records retained? 10. Mergers and Acquisitions: Pre-Acquisition Due Diligence and Post-Acquisition Integration Have adequate procedures been established, implemented and maintained for the conduct of FCPA due diligence on mergers and acquisitions? Do such procedures require due diligence to be conducted pre-acquisition or where circumstances prevent this, as soon as practicable post-acquisition? Do such procedures provide for the immediate disclosure to the authorities of any corrupt payments or practices uncovered during the due diligence? Do such procedures require the immediate integration of the acquired business into the organization's compliance program and internal control systems? Have the following integration actions been implemented for acquired business units? a) Training of new employees b) Re-evaluation of third parties under company standards c) Conduct of audits
APEC General Elements of Effective Voluntary Corporate Compliance Programs
2014/CSOM/041 Agenda Item: 3 APEC General Elements of Effective Voluntary Corporate Compliance Programs Purpose: Consideration Submitted by: United States Concluding Senior Officials Meeting Beijing, China
More informationHIGHLIGHTS OF THE FCPA RESOURCE GUIDE
HIGHLIGHTS OF THE FCPA RESOURCE GUIDE Corporate fraud, regulatory oversight and government enforcement actions are on the rise. Alvarez & Marsal (A&M) stands ready to help you navigate and resolve these
More informationLAUREATE ANTI-CORRUPTION POLICY
LAUREATE ANTI-CORRUPTION POLICY Laureate Anti-Corruption Policy 1.0 PURPOSE AND BACKGROUND This Anti-Corruption Policy establishes basic standards and a framework for the prevention and detection of bribery
More informationANTI BRIBERY AND FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY
ANTI BRIBERY AND FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY THIS POLICY DOES NOT CREATE A CONTRACT OF EMPLOYMENT OR ALTER THE AT WILL NATURE OF ANY EMPLOYEE S EMPLOYMENT IN ANY WAY. 1. Statement of
More informationGoodyear s Anti-bribery Policy July 1, 2011
Goodyear s Anti-bribery Policy July 1, 2011 Anti-bribery Policy Goodyear does not wish to obtain business advantages by offering or receiving improper payments or anything of value, even in countries where
More informationDIGITAL RIVER, INC. FOREIGN CORRUPT PRACTICES ACT AND ANTI-BRIBERY POLICY. (Adopted by resolution of the Board of Directors on December 1, 2011)
DIGITAL RIVER, INC. FOREIGN CORRUPT PRACTICES ACT AND ANTI-BRIBERY POLICY (Adopted by resolution of the Board of Directors on December 1, 2011) Digital River, Inc. and our affiliates ( DR ) must comply
More informationFraud-Related Compliance
Fraud-Related Compliance Areas of Compliance, Part 1: FCPA, SOX, PCAOB, Dodd-Frank 2015 Association of Certified Fraud Examiners, Inc. Foreign Corrupt Practices Act (FCPA) Enacted to prohibit corrupt payments
More informationLANTHEUS HOLDINGS, INC. Foreign Corrupt Practices Act and Anti-Bribery Compliance Policy
LANTHEUS HOLDINGS, INC. Foreign Corrupt Practices Act and Anti-Bribery Compliance Policy 1. Introduction. Applicability. This Foreign Corrupt Practices Act and Anti-Bribery Compliance Policy (this Policy
More informationSimplify the Complexity of Managing 3rd Party Anti-Bribery / FCPA Compliance
Simplify the Complexity of Managing 3rd Party Anti-Bribery / FCPA Compliance Arm Stakeholders with Critical Information to Assess 3rd Party Relationships and Comply with the Foreign Corrupt Practices Act
More informationPlatform Specialty Products Corporation Foreign Corrupt Practices Act/Anti-Corruption Policy
1. Introduction. Platform Specialty Products Corporation Foreign Corrupt Practices Act/Anti-Corruption Policy 1.1 Combating Corruption. Platform Specialty Products Corporation, including its subsidiaries,
More informationThe Long Arm of the U.S. Foreign Corrupt Practices Act: Complying with the FCPA in the Vietnamese Landscape
The Long Arm of the U.S. Foreign Corrupt Practices Act: Complying with the FCPA in the Vietnamese Landscape Foreign Corrupt Practices Act: The Act What is the Act? Anti-Bribery Provisions Book and Record
More informationDOJ and SEC Release FCPA Resource Guide: What Does Your Company Do Now? January 8, 2013 By: Evelyn Suarez & Patrick Hanes
DOJ and SEC Release FCPA Resource Guide: What Does Your Company Do Now? January 8, 2013 By: Evelyn Suarez & Patrick Hanes Speakers Evelyn M. Suarez International Law Williams Mullen, Washington D.C. esuarez@williamsmullen.com
More informationOMNI TECHNICAL SOLUTIONS. Business Ethics, Compliance, Anti-Corruption and Anti-Money Laundering Policy
OMNI TECHNICAL SOLUTIONS Business Ethics, Compliance, Anti-Corruption and Anti-Money Laundering Policy Updated: September 2015 Table of Contents 1. Introduction... 2 2. Business Ethics... 3 2.1 Compliance...
More information30 Important Considerations for Effective FCPA Compliance
30 Important Considerations for Effective FCPA Compliance Effective design, good-faith implementation As enforcement of the Foreign Corrupt Practices Act (FCPA) has gone through the roof in recent years,
More informationEAGLE PARENT, INC EPICOR SOFTWARE CORPORATION ACTIVANT SOLUTIONS, INC. UK ANTI-BRIBERY AND CORRUPTION POLICY. (As Adopted July 2011)
EAGLE PARENT, INC EPICOR SOFTWARE CORPORATION ACTIVANT SOLUTIONS, INC. UK ANTI-BRIBERY AND CORRUPTION POLICY (As Adopted July 2011) Introduction This UK Anti-Bribery and Corruption Policy ( Policy ) is
More informationM&A in 2015: Successor Liability Under the FCPA. Norton Rose Fulbright US LLP Thursday, February 26, 2015
M&A in 2015: Successor Liability Under the FCPA Norton Rose Fulbright US LLP Thursday, February 26, 2015 Speaker Marsha Z. Gerber Partner Norton Rose Fulbright US LLP Marsha Gerber is a partner in the
More informationBBC. Anti-Bribery Policy. June 2011
BBC Anti-Bribery Policy June 2011 CONTENTS CLAUSE 1. Anti-Bribery Policy statement... 1 2. Who is covered by the policy?... 2 3. What is bribery?... 2 4. Gifts and hospitality... 3 5. Gifts and hospitality
More informationAnti-Bribery and Corruption Policy
Newcrest strictly prohibits bribery and other unlawful or improper payments made to any individual or entity, as outlined in this Anti-Bribery & Corruption Policy. Newcrest's Anti- Bribery & Corruption
More informationHILLENBRAND, INC. AND SUBSIDIARIES. Global Anti-Corruption Policy Statement and Compliance Guide
HILLENBRAND, INC. AND SUBSIDIARIES Global Anti-Corruption Policy Statement and Compliance Guide Hillenbrand, Inc., including all of its subsidiaries (referred to collectively as the Company ), maintains
More informationANTI-CORRUPTION COMPLIANCE SYSTEM CERTIFICATION
. CERTIFYING Basel Beijing Brussels Frankfurt ETHIC Intelligence Certification Committee Geneva London Istanbul Milan Paris Decision of Award and Registration ANTI-CORRUPTION COMPLIANCE SYSTEM CERTIFICATION
More informationANTI-CORRUPTION AND ANTI-BRIBERY POLICY
COMPLIANCE 18.0 ANTI-CORRUPTION AND ANTI-BRIBERY POLICY I. SCOPE This policy applies to all directors, officers, employees, agents, and shareholders of UHS of Delaware, Inc. (hereafter, UHS ), its subsidiaries
More informationThe FCPA, Al Capone and the IRS June 11, 2014
The FCPA, Al Capone and the IRS June 11, 2014 Ron Stefani, CFO Partner ron.stefani@aventinehillinc.com 832 922 2200 (mobile) 713 580 9400 (office) Origins of the FCPA? Congress enacted the U.S. Foreign
More informationDRAFT. Anti-Bribery and Anti-Corruption Policy. Introduction. Scope. 1. Definitions
DRAFT Change History: Anti-Bribery and Anti-Corruption Policy Control Risks Group Ltd Commercial in confidence Introduction This document defines Control Risks policy on the avoidance of bribery and corruption.
More informationANTI-CORRUPTION POLICY AND PROCEDURES
ANTI-CORRUPTION POLICY AND PROCEDURES EXECUTIVE SUMMARY The nature of the oil, gas and power industries requires STS Consulting Services, LLC ( Company ) to operate in a wide range of legal and business
More informationSPG 223 Fraud Risk Management. June 2015
SPG 223 Fraud Risk Management June 2015 Disclaimer and copyright This prudential practice guide is not legal advice and users are encouraged to obtain professional advice about the application of any legislation
More informationANTI-BRIBERY AND FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY
Issued: November 12, 2013 ANTI-BRIBERY AND FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY SCOPE This policy applies to all Magnetek, Inc. ( Magnetek ) employees, its subsidiaries and affiliates worldwide,
More informationGuidance Note: Corporate Governance - Board of Directors. March 2015. Ce document est aussi disponible en français.
Guidance Note: Corporate Governance - Board of Directors March 2015 Ce document est aussi disponible en français. Applicability The Guidance Note: Corporate Governance - Board of Directors (the Guidance
More informationWorldwide Anti-Corruption Policy
Worldwide Anti-Corruption Policy I. PURPOSE The laws of most countries make the payment or offer of payment or even receipt of a bribe, kickback or other corrupt payment a crime, subjecting both Eaton
More informationII. Compliance Examinations - Compliance Management System. Compliance Management System. Introduction. Board of Directors and Management Oversight
Compliance Management System Introduction Financial institutions operate in a dynamic environment influenced by industry consolidation, convergence of financial services, emerging technology, and market
More informationThe Foreign Corrupt Practices Act, the Anti-Kickback Statute, and Healthcare Fraud Enforcement. Anti-Bribery Provisions
The Foreign Corrupt Practices Act, the Anti-Kickback Statute, and Healthcare Fraud Enforcement James M. Lord* Martie Ross Charles R Hacker, Jr. Assistant United States Spencer Fane Partner Attorney Britt
More informationBribery and Corruption
Bribery and Corruption M&A Corruption Due Diligence Introduction M&A transactions deal with the buying, selling, dividing, and combining of different companies and similar entities. M&A transactions are
More informationMICROSEMI CORPORATION FOREIGN CORRUPT PRACTICES ACT CORPORATE LEGAL MANUAL 1. POLICY 2. PURPOSE 3. SCOPE 4. PROVISIONS
1. POLICY Compliance with Foreign Corrupt Practices Act ( FCPA ) is required by law and also coincides with our culture of conducting business in an ethical manner. Everyone at Microsemi, including the
More informationHelix Energy Solutions Group, Inc. Code of Business Conduct and Ethics
Helix Energy Solutions Group, Inc. Code of Business Conduct and Ethics Introduction This Code of Business Conduct and Ethics ( Code ) covers a wide range of business practices and procedures. It does not
More informationPHILIPPINE LONG DISTANCE TELEPHONE COMPANY CODE OF BUSINESS CONDUCT AND ETHICS
PHILIPPINE LONG DISTANCE TELEPHONE COMPANY CODE OF BUSINESS CONDUCT AND ETHICS Philippine Long Distance Telephone Company ( PLDT or the Company ) is dedicated to doing business in accordance with the highest
More informationComplying with the U.S. Foreign Corrupt Practices Act
Complying with the U.S. Foreign Corrupt Practices Act 1. About This Manual This Manual describes the Foreign Corrupt Practices Act ( FCPA ), 15 U.S.C. 78m, 78dd, 78ff (collectively, FCPA ), anti-corruption
More informationMUELLER INDUSTRIES, INC. ANTICORRUPTION POLICY
MUELLER INDUSTRIES, INC. ANTICORRUPTION POLICY THIS POLICY HAS BEEN APPROVED BY THE BOARD OF DIRECTORS OF MUELLER INDUSTRIES, INC. ON FEBRUARY 11, 2010 AND IS APPLICABLE TO ALL DIRECTORS, OFFICERS, EMPLOYEES,
More informationINFORMATION TECHNOLOGY SECURITY STANDARDS
INFORMATION TECHNOLOGY SECURITY STANDARDS Version 2.0 December 2013 Table of Contents 1 OVERVIEW 3 2 SCOPE 4 3 STRUCTURE 5 4 ASSET MANAGEMENT 6 5 HUMAN RESOURCES SECURITY 7 6 PHYSICAL AND ENVIRONMENTAL
More informationFOREIGN CORRUPT PRACTICES ACT AND ANTI-CORRUPTION COMPLIANCE POLICY. Adopted April 30, 2014
FOREIGN CORRUPT PRACTICES ACT AND ANTI-CORRUPTION COMPLIANCE POLICY Adopted April 30, 2014 134782_1 TABLE OF CONTENTS I. POLICY STATEMENT... 1 II. KEY TERMS... 2 III. SCOPE AND APPLICABILITY OF THIS POLICY...
More informationFOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY
FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY Acuity Brands, Inc. is committed to maintaining the highest level of ethical and legal standards in the conduct of our business activities. The Company s
More informationCorporate Code of Conduct
1. Background Corporate Code of Conduct 1.1. For over a century, the Swire group of companies has been recognised as acting responsibly in the course of achieving its commercial success. Our reputation
More informationELEPHANT TALK COMMUNICATIONS CORP. FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY
ELEPHANT TALK COMMUNICATIONS CORP. FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY I. POLICY STATEMENT This Foreign Corrupt Practices Act Compliancy Policy (the Policy ) has been adopted by Elephant Talk
More informationForeign Corrupt Practices Act (FCPA)
Compliance Guideline Foreign Corrupt Practices Act (FCPA) Dachser GmbH & Co. KG Introduction The purpose of this guideline is to provide employees of DACHSER GmbH & Co. KG ( DACHSER ) involved in international
More informationGUIDELINES ON COMPLIANCE FUNCTION FOR FUND MANAGEMENT COMPANIES
GUIDELINES ON COMPLIANCE FUNCTION FOR FUND MANAGEMENT COMPANIES Issued: 15 March 2005 Revised: 25 April 2014 1 P a g e List of Revision Revision Effective Date 1 st Revision 23 May 2011 2 nd Revision 16
More informationSECTION B DEFINITION, PURPOSE, INDEPENDENCE AND NATURE OF WORK OF INTERNAL AUDIT
SECTION B DEFINITION, PURPOSE, INDEPENDENCE AND NATURE OF WORK OF INTERNAL AUDIT Through CGIAR Financial Guideline No 3 Auditing Guidelines Manual the CGIAR has adopted the IIA Definition of internal auditing
More informationCARIBBEAN DEVELOPMENT BANK STRATEGIC FRAMEWORK FOR INTEGRITY, COMPLIANCE AND ACCOUNTABILITY (2015)
CARIBBEAN DEVELOPMENT BANK STRATEGIC FRAMEWORK FOR INTEGRITY, COMPLIANCE AND ACCOUNTABILITY (2015) Provides a comprehensive strategic framework for institutional integrity (fraud and corruption), ethics,
More informationFOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY
PURPOSE POLICY FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY This Policy ensures that China Xiniya Fashion Limited ( Xiniya ) complies with the Foreign Corrupt Practices Act 1977 ( FCPA ). Penalties
More informationCOMPLIANCE PROGRAM FOR XL GROUP PLC
1 COMPLIANCE PROGRAM FOR XL GROUP PLC I. PURPOSE The purpose of the XL Group plc Compliance Program (the Program ) is to (a) help protect XL Group plc companies from financial or reputational harm that
More informationE Distribution: GENERAL POLICY ISSUES. Agenda item 4 WFP ANTI-FRAUD AND ANTI-CORRUPTION POLICY. For approval
Executive Board Second Regular Session Rome, 8 11 November 2010 POLICY ISSUES Agenda item 4 For approval WFP ANTI-FRAUD AND ANTI-CORRUPTION POLICY E Distribution: GENERAL WFP/EB.2/2010/4-C/1 29 September
More informationOverview of Recently Issued FCPA Guidance by DOJ and the SEC
Overview of Recently Issued FCPA Guidance by DOJ and the SEC George J. Terwilliger III Daniel Levin Alison Tanchyk www.morganlewis.com December 13, 2012 Presenters George J. Terwilliger III Washington,
More informationAdministrative Policy No. AD 2.26 Title:
I. SCOPE: Administrative Policy No. AD 2.26 Page: 1 of 5 This policy applies to all directors, officers, employees, agents, and shareholders of Tenet Healthcare Corporation, its subsidiaries and/or affiliates
More informationPROTIVITI FLASH REPORT
PROTIVITI FLASH REPORT Even Retailers and Consumer Products Manufacturers Must Manage Compliance with the U.S. Foreign Corrupt Practices Act and Other Anti-Bribery Laws May 3, 2012 Recent reports of alleged
More informationCOMPLIANCE MANAGEMENT SYSTEM
COMPLIANCE MANAGEMENT SYSTEM INTRODUCTION Financial institutions operate in a dynamic environment influenced by industry consolidation, convergence of financial services, emerging technology, and market
More informationCARDINAL RESOURCES LLC INTRODUCTION
CARDINAL RESOURCES LLC ANTI- BRIBERY AND ANTI- CORRUPTION POLICY INTRODUCTION The purpose of this Anti- bribery and Anti- corruption Policy (the "Policy") is to ensure compliance by the Red Bird Group
More informationcompany policy number 0001 LEGAL AND ETHICAL CONDUCT
company policy number 0001 LEGAL AND ETHICAL CONDUCT eff. date replaces page 28 Mar. 2011 14 Feb. 2006 1 of 10 PURPOSE CPI has adopted this Code of Legal and Ethical Conduct ( Code ) to promote: honest
More informationINSURANCE ACT 2008 CORPORATE GOVERNANCE CODE OF PRACTICE FOR REGULATED INSURANCE ENTITIES
SD 0880/10 INSURANCE ACT 2008 CORPORATE GOVERNANCE CODE OF PRACTICE FOR REGULATED INSURANCE ENTITIES Laid before Tynwald 16 November 2010 Coming into operation 1 October 2010 The Supervisor, after consulting
More informationThe ITAR and the FCPA: What You Disclose May Hurt You. October 7, 2014
The ITAR and the FCPA: What You Disclose May Hurt You October 7, 2014 Presenters Mark Srere Bryan Cave LLP Susan Kovarovics Bryan Cave LLP 2 Agenda Background on the FCPA Background on ITAR ITAR Part 129
More informationForeign Corrupt Practices Act (FCPA) And Company Law
FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY The Company will conduct every business transaction (including without limitation, operations, negotiations, and marketing) with integrity and will comply
More informationPART I - PRELIMINARY...1 Objective...1 Applicability...2 Legal and Regulatory Provision...2
PART I - PRELIMINARY...1 Objective...1 Applicability...2 Legal and Regulatory Provision...2 PART II POLICY REQUIREMENTS...3 Investment and Risk Management Policy...3 Monitoring and Control...5 Roles of
More informationBayer HealthCare s Comprehensive Compliance Program Pursuant to California Health and Safety Code 119400-119402
Bayer HealthCare s Comprehensive Compliance Program Pursuant to California Health and Safety Code 119400-119402 I. INTRODUCTION Bayer HealthCare LLC [including Bayer HealthCare LLC Dermatology Division
More informationMACLEAN-FOGG COMPANY FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY
MACLEAN-FOGG COMPANY FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY MacLean-Fogg s corporate policy prohibits all improper or unethical payments to government officials anywhere in the world. This is
More informationInternal Control Systems and Maintenance of Accounting and Other Records for Interactive Gaming & Interactive Wagering Corporations (IGIWC)
Internal Control Systems and Maintenance of Accounting and Other Records for Interactive Gaming & Interactive Wagering Corporations (IGIWC) 1 Introduction 1.1 Section 316 (4) of the International Business
More informationPolicy-Standard heading. Fraud and Corruption Policy
Policy-Standard heading Fraud and Corruption Policy September 2013 Table of contents Introduction 3 Purpose 3 Scope 3 Related Policies and Processes 3 Definition of Fraud and Corruption 4 Policy 4 Code
More informationSTATEMENT FROM THE CHAIRMAN
STATEMENT FROM THE CHAIRMAN In an ever-changing global marketplace, it is important for all of us to have an understanding of the responsibilities each of have in carrying out day-to-day business decisions
More informationFEDERAL DEPOSIT INSURANCE CORPORATION WASHINGTON, D.C. ) CONSENT ORDER. ) FDIC-13-0450b
FEDERAL DEPOSIT INSURANCE CORPORATION WASHINGTON, D.C. In the Matter of THE BANK OF PRINCETON PRINCETON, NEW JERSEY (INSURED STATE NONMEMBER BANK) ) ) ) ) CONSENT ORDER ) ) ) FDIC-13-0450b ) The Federal
More informationGUIDELINES ON RISK MANAGEMENT AND INTERNAL CONTROLS FOR INSURANCE AND REINSURANCE COMPANIES
20 th February, 2013 To Insurance Companies Reinsurance Companies GUIDELINES ON RISK MANAGEMENT AND INTERNAL CONTROLS FOR INSURANCE AND REINSURANCE COMPANIES These guidelines on Risk Management and Internal
More informationTITLE III INFORMATION SECURITY
H. R. 2458 48 (1) maximize the degree to which unclassified geographic information from various sources can be made electronically compatible and accessible; and (2) promote the development of interoperable
More informationPuerto Rican Family Institute, Inc.
Puerto Rican Family Institute, Inc. Stronghold for Families, a Pathfinder for Children Corporate Compliance Program Plan - 2014 Updated by: Approved by: Yolanda Alicea Winn, LCSWR Vice President/Corporate
More informationGUIDANCE FOR MANAGING THIRD-PARTY RISK
GUIDANCE FOR MANAGING THIRD-PARTY RISK Introduction An institution s board of directors and senior management are ultimately responsible for managing activities conducted through third-party relationships,
More informationEURIBOR - CODE OF OBLIGATIONS OF PANEL BANKS
D2725D-2013 EURIBOR - CODE OF OBLIGATIONS OF PANEL BANKS Version: 1 October 2013 1. Objectives The European Money Markets Institute EMMI previously known as Euribor-EBF, as Administrator for the Euribor
More informationIFA s 45 th Annual LEGAL SYMPOSIUM
LEGAL SYMPOSIUM The Foreign Corrupt Practices Act: What Every International Franchisor Must Know Moderator: Speakers: Eric L. Yaffe Gray Plant Mooty Washington, DC Mary C. Spearing Baker Botts L.L.P. Washington,
More informationRisk Considerations for Internal Audit
Risk Considerations for Internal Audit Cecile Galvez, Deloitte & Touche LLP Enterprise Risk Services Director Traci Mizoguchi, Deloitte & Touche LLP Enterprise Risk Services Senior Manager February 2013
More informationNOTICE 158 OF 2014 FINANCIAL SERVICES BOARD REGISTRAR OF LONG-TERM INSURANCE AND SHORT-TERM INSURANCE
STAATSKOERANT, 19 DESEMBER 2014 No. 38357 3 BOARD NOTICE NOTICE 158 OF 2014 FINANCIAL SERVICES BOARD REGISTRAR OF LONG-TERM INSURANCE AND SHORT-TERM INSURANCE LONG-TERM INSURANCE ACT, 1998 (ACT NO. 52
More informationEXTRA SPACE STORAGE INC. CODE OF BUSINESS CONDUCT AND ETHICS
EXTRA SPACE STORAGE INC. CODE OF BUSINESS CONDUCT AND ETHICS Purpose and Scope Since its founding, Extra Space Storage Inc. and its subsidiaries (collectively, the Company ) has required that all its employees
More informationPHOENIX NEW MEDIA LIMITED FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY
PHOENIX NEW MEDIA LIMITED FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY Phoenix New Media Limited (together with its subsidiaries, the Company ) is committed to conducting all aspects of its business
More informationANTI-BRIBERY AND CORRUPTION POLICY
ANTI-BRIBERY AND CORRUPTION POLICY OBJECTIVES Woodside is committed to conducting its business and activities with integrity. To achieve this objective: Woodside will not engage in corrupt business practices;
More informationFCPA and International Compliance
FCPA and International Compliance Briefing to San Antonio Post, SAME C. Ernest Edgar IV General Counsel, Atkins North America 1 Agenda Understanding the FCPA The Nuts and Bolts of the FCPA Who Is Covered
More informationPartnering Against Corruption Initiative Global Principles for Countering Corruption
Industry Agenda Partnering Against Corruption Initiative Global Principles for Countering Corruption Application January 2014 World Economic Forum 2014 - All rights reserved. No part of this publication
More informationSEKO Logistics Anti-Corruption and Foreign Corrupt Practices Act Policy
SEKO Logistics Anti-Corruption and Foreign Corrupt Practices Act Policy General Policy: SEKO Logistics ( SEKO ) conducts its business ethically and in compliance with all laws in the countries where SEKO
More informationAnti-Corruption and FCPA Compliance Policy
Anti-Corruption and FCPA Compliance Policy Purpose and Scope Vicor Corporation ( Vicor or the Company ) must comply with the U.S. Foreign Corrupt Practices Act of 1977, as amended (the "FCPA") and all
More informationU.S. Foreign Corrupt Practices Act for Beginners
U.S. Foreign Corrupt Practices Act for Beginners This presentation, related materials and subsequent discussion are provided for educational purposes only. They do not constitute legal advice nor do they
More informationHOWARD UNIVERSITY POLICY
HOWARD UNIVERSITY POLICY Policy Number: 400-007 Policy Title: CONDUCTING GLOBAL BUSINESS IN COMPLIANCE WITH FOREIGN CORRUPT PRACTICES ACT Responsible Officer: General Counsel and Chief Compliance Officer
More informationStandards of. Conduct. Important Phone Number for Reporting Violations
Standards of Conduct It is the policy of Security Health Plan that all its business be conducted honestly, ethically, and with integrity. Security Health Plan s relationships with members, hospitals, clinics,
More informationCode of Business Conduct
4 8 F A C T O R I N G Code of Business Conduct Dear Colleague: Since its foundation 48 Factoring has been committed to maintaining the highest ethical standards. Our core values exemplify our drive for
More informationFraud Risk Management Procedures
Fraud Risk Management Procedures 1. Introduction KCE Electronics Public Company Limited ( KCE or the Company ) is committed to achieving the highest levels of business integrity, morals and transparency
More informationNCI BUILDING SYSTEMS, INC. FOREIGN CORRUPT PRACTICES ACT POLICY STATEMENT AND COMPLIANCE GUIDE
NCI BUILDING SYSTEMS, INC. FOREIGN CORRUPT PRACTICES ACT POLICY STATEMENT AND COMPLIANCE GUIDE Introduction The Foreign Corrupt Practices Act as amended by the International Anti-bribery and Fair Competition
More informationGlobal Anti-Corruption Compliance Requirements for International Business
Global Anti-Corruption Compliance Requirements for International Business Doreen Edelman Co-Chair of the Global Business Team Joe Whitley Chair of the Government Enforcement & Investigations Group The
More information23 rd Annual ACFE Fraud Conference and Exhibition 4F: Compliance Challenges with Dodd-Frank Section 922. Orlando, FL June 17 22, 2012
23 rd Annual ACFE Fraud Conference and Exhibition 4F: Compliance Challenges with Dodd-Frank Section 922 Orlando, FL June 17 22, 2012 Presentation by Shruti Shah Senior Policy Director, Transparency International
More informationTRANSNATIONAL JOINT VENTURES. & the importance of fcpa compliance
TRANSNATIONAL JOINT VENTURES & the importance of fcpa compliance EXECUTIVE SUMMARY Many of the FCPA investigations pursued by the DOJ/SEC in recent years involve transnational joint ventures. Prior to
More informationMEDICAID COMPLIANCE POLICY
6232 MEDICAID COMPLIANCE POLICY It is the policy of the Board of Education that all school district s practices regarding Medicaid claims for services be in compliance with all applicable federal and state
More informationPreparation of a Rail Safety Management System Guideline
Preparation of a Rail Safety Management System Guideline Page 1 of 99 Version History Version No. Approved by Date approved Review date 1 By 20 January 2014 Guideline for Preparation of a Safety Management
More informationTHIRD PARTY. T i m L i e t z R e g i o n a l P r a c t i c e L e a d e r R i s k A d v i s o r y S e r v i c e s
MANAGING THIRD PARTY RISK T i m L i e t z R e g i o n a l P r a c t i c e L e a d e r R i s k A d v i s o r y S e r v i c e s Experis -- a different kind of talent company. Experis Tuesday, January 08,
More informationB o a r d of Governors of the Federal Reserve System. Supplemental Policy Statement on the. Internal Audit Function and Its Outsourcing
B o a r d of Governors of the Federal Reserve System Supplemental Policy Statement on the Internal Audit Function and Its Outsourcing January 23, 2013 P U R P O S E This policy statement is being issued
More information2013 Communication on Progress
2013 Communication on Progress Participant The Coca-Cola Company Published 2014/01/02 Time period January 2012 November 2013 Files 2012-2013-gri-report_Coca-Cola.pdf (English) Links http://www.coca-colacompany.com/sustainability
More informationSamsung Engineering Co., Ltd.
Introduction to Our Compliance Program Samsung Engineering Co., Ltd. 500 Samsung GEC, Sangil-dong, Gangdong-gu, Seoul, Korea 134-090 +82-2-2053-3000 www.samsungengineering.com 03 Since its establishment
More informationAntifraud program and controls assessment grid*
Advisory Services Antifraud program and * Fraud risks & controls February 2008 *connectedthinking 2008 PricewaterhouseCoopers LLP. All rights reserved. PricewaterhouseCoopers refers to PricewaterhouseCoopers
More informationANTI-BRIBERY. Table of Contents Page #
Responsible University Official: Vice President for Finance Operations and Treasurer Responsible Office: Office of Financial Operations Origination Date: March 31, 2015 ANTI-BRIBERY Policy Statement Northwestern
More informationFubon Financial Holding Co., Ltd. (the Company ) Ethical Corporate Management Best Practice Principles (the Principles )
Fubon Financial Holding Co., Ltd. (the Company ) Ethical Corporate Management Best Practice Principles (the Principles ) Adopted by the Board of Directors on March 11, 2011 Article 1 (Purpose and Scope)
More informationCompliance and Ethics at the Federal Reserve Bank of New York
Compliance and Ethics at the Federal Reserve Bank of New York Operational Risk and Internal Audit Course Marina Adams, Compliance Officer and AVP David K. Clune, Compliance and Ethics Officer Kevin White,
More informationBUILDING AN EFFECTIVE COMPLIANCE AND ETHICS PROGRAM
BUILDING AN EFFECTIVE COMPLIANCE AND ETHICS PROGRAM IN THE BEGINNING Building an Effective Compliance and Ethics Program 1. Why have a compliance and ethics program? 2. What are the critical building blocks?
More information