final key elements of an effective iso 37001

Key Elements of an effective

Anti-Bribery Management

System ISO 37001

Implementation

1 October 13, 2016, Mohamad Khachab, Managing Partner, ICS

Mohamad Khachab PECB Partner and Trainer

Mohamad Khachab has 30 years of professional experience in

management consultancy, project management, teaching/training, IT

Procurement, preparing proposals, information risk management,

research, developing bidding documents, and business development

activities.

Contact Information

703-962-0793

khachabmy@ics4business.com http://www.ics4business.com/

linkedin.com/in/moekhachab

Definition ISO 37001

ISO 37001 is an anti-bribery management system standard designed to help an organization establish, implement, maintain, and improve an anti-bribery compliance program or “management system.”

3 October 13, 2016, Mohamad Khachab, Managing Partner, ICS

• Is Bribery still common in the workplace today?

Private sector? Public Sector?

• Do you have a compliance program? Is it defensible?

• Can you demonstrate your compliance to your board? Government (s) ? Regulatory bodies?

• How about your agents?

• Are you monitoring proactively? How you handle exceptions?

• Do you analyze your expenditures?

• Can you identify patterns of improper behavior or collusion?

• Have you done enough training and education?

4 October 13, 2016, Mohamad Khachab,

Managing Partner, ICS

5 October 13, 2016, Mohamad Khachab,

Managing Partner, ICS

Morgan Stanley can serve as a model for any organization to follow as a best practice:

• Document everything

• Conduct regular program auditing

• Educate employees

• Implement global financial systems controls

6 October 13, 2016, Mohamad Khachab,

Managing Partner, ICS

The Private Sector has a central role to play in preventing

detecting and responding to bribery in int’l business.

In 2009, the OECD and the Working Group on Bribery

released good practice guidance on internal controls,

ethics, and compliance.

7 October 13, 2016, Mohamad Khachab,

Managing Partner, ICS

8 October 13, 2016, Mohamad Khachab,

Managing Partner, ICS

9 October 13, 2016, Mohamad Khachab,

Managing Partner, ICS

A-B

Argentina

Australia

Austria

Belgium

Brazil

Bulgaria

C-F

Canada

Chile

Colombia

Czech Republic

Denmark

Estonia

Finland

France

G-K

Germany

Greece

Hungary

Iceland

Ireland

Israel

Italy

Japan

Korea

L-R

Latvia

Luxembourg

Mexico

Netherlands

New Zealand

Norway

Poland

Portugal

Russia

S-Z

Slovak Republic

Slovenia

South Africa

Spain

Sweden

Switzerland

Turkey

United Kingdom

United States

http://www.oecd.org/daf/anti-bribery/countryreportsontheimplementationoftheoecdanti-briberyconvention.htm

Country reports on the implementation of the

OECD Anti-Bribery Convention

Every country that is party to the Anti-bribery Convention has an interest in

ensuring that all parties live up to their obligations. Country monitoring reports

contain recommendations formed from rigorous peer-review examinations of

each country. These country monitoring reports and implementation efforts can

be accessed below.

10 October 13, 2016, Mohamad Khachab,

Managing Partner, ICS

Estonia in a Nutshell in 2014 • 29 individuals and 15 entities were sanctioned under criminal proceedings for foreign

bribery in 2014.

• At least 10 of the sanctioned individuals were sentenced to prison for foreign bribery.

• At least 16 individuals and 15 entities (mainly companies) have been sanctioned in criminal, administrative and civil cases for other offences related to foreign bribery, such as money laundering or accounting misconduct, in 8 Parties.

• 361 individuals and 126 entities have been sanctioned under criminal proceedings for foreign bribery in 17 Parties between the time the convention entered into force in 1999 and the end of 2014.

• At least 95 of the sanctioned individuals were sentenced to prison for foreign bribery.

• At least 110 individuals and 200 entities have been sanctioned in criminal, administrative and civil cases for other offences related to foreign bribery, such as money-laundering or accounting, in 8 Parties.

• Approximately 393 investigations are ongoing in 25 Parties to the Anti-Bribery Convention.

• Prosecutions are ongoing against 142 individuals and 14 entities in 12 Parties for offences under the Convention.

11 October 13, 2016, Mohamad Khachab, Managing Partner, ICS

John Verver, CPA, CISA, CMC WWW.acl.com

12 October 13, 2016, Mohamad Khachab, Managing Partner, ICS

13 October 13, 2016, Mohamad Khachab,

Managing Partner, ICS

14 October 13, 2016, Mohamad Khachab,

Managing Partner, ICS

Code of Business Conduct Anti-Bribery

Policy

Anti-Corruption

Toolkit

Risk

Mapping

Risk

Assessment

Partnerships

CULTURE

Reporting &

Documentation

Globalization

Education & Training

ISO 37001

Monitoring &

Testing

Commitment

Resources /

Know-How

Control

Environment

Ethics

Internal Audit

15 October 13, 2016, Mohamad Khachab,

Managing Partner, ICS

You need to implement a plan

Earn/Guarantee senior level support for your plan,

budget, needed dedicated resources.

Keep them informed.

PMO to manage the project, documents, and

deliverables.

Increase awareness within organization and with

stakeholders.

16 October 13, 2016, Mohamad Khachab,

Managing Partner, ICS

Culture

• Be diligent in your efforts to promote an ethical culture and ensure that people work within the confines of the rules.

• People go to work with a core function; are hired to do a job.

• People face dilemmas on jobs, and are supposed to make decisions.

17

October 13, 2016, Mohamad Khachab, Managing Partner, ICS

Ethics Office

• Every government agency or private organization should have an ethics office and every ethics office shall be staffed with ethics officials.

• These individuals shall be available every day to answer questions related to standards of conduct in a confidential secure fashion.

18 October 13, 2016, Mohamad Khachab,

Managing Partner, ICS

Training

• Increased need reported.

• Annual training must be given to all employees who hold positions of significant responsibility or authority.

• Annual required verbal training for public filers each calendar year.

• Agencies are encouraged to vary the content of verbal training from year to year but the training must include, at least, a review of the following items:

19 October 13, 2016, Mohamad Khachab,

Managing Partner, ICS

Training - 2

(1) General principles for ethical conduct

(2) The Standards of conduct

(3) Any supplemental standards;

(4) Conflict of interest statutes; and

(5) Contact information of persons / advisors on ethics issues.

Employees must be given at least one hour of official duty time for verbal training.

20 October 13, 2016, Mohamad Khachab,

Managing Partner, ICS

Training - 3

The training must be:

(1) Presented by a qualified instructor; or

(2) Prepared by a qualified instructor and presented either in-class, web-based, or thru videotape.

• If the training is prepared by a qualified instructor and presented in non-classroom setting, a qualified instructor must be available during and immediately after the training to answer questions.

21

October 13, 2016, Mohamad Khachab, Managing Partner, ICS

Education

• Education is foundation of any ethics program. It must be visible, consistent, and flexible.

• Assess the education needs of your ethics officials by administering an annual training needs assessment questionnaire and collecting post-training evaluation data.

• Training must be the central part of your ethics program

22 October 13, 2016, Mohamad Khachab,

Managing Partner, ICS

Customization

Customization of education and training allow employees to learn in the context of their agency or job and this is important to ensure that people actually process the information given to them and feel equipped to deal with challenges as they arise.

23 October 13, 2016, Mohamad Khachab,

Managing Partner, ICS

Awards / Reinforcement Program

• Develop an awards program to allow your organization to use positive reinforcement to encourage offices/branches to focus on education.

24 October 13, 2016, Mohamad Khachab,

Managing Partner, ICS

MEDIA

• Use media intelligently.

• Send a strong message.

• Use posters to send message. Post them strategically. They are quick and very economic to produce and can be customized to treat specific issues at specific locations.

25 October 13, 2016, Mohamad Khachab,

Managing Partner, ICS

Technology

The days where auditing a selected sample of few

transactions is long gone. Today regulators require

organizations to install comprehensive monitoring tools to

mitigate risk especially for those organizations that

work in multi-international/national environments.

Awareness raising activities highlight the benefits of

compliance, including potentially saving the company from

both the risk of bribery and the costs Involved in exposure

and sanctioning.

Today’s boards have to be aware of environment,

standards, new trends, technological factors, and risk(s).

26 October 13, 2016, Mohamad Khachab,

Managing Partner, ICS

27 October 13, 2016, Mohamad Khachab,

Managing Partner, ICS

28 October 13, 2016, Mohamad Khachab,

Managing Partner, ICS

Welcome to EthicsLine EthicsLine is a reporting service offered by The Coca-Cola Company and administered by a third party, Global Compliance.

•You may access EthicsLine by telephone or on this website.Telephone Call toll free at 1(866)790-5579 in the United States and Canada, or go to the list of toll free international access codes. •Online To get started, we need some basic information from you. 1. Where are you located? 2. Where did the event you are contacting us about take place? Click "continue" to proceed. Continue Issues Concerning Immediate Violence or Threat Contact the Strategic Security KO Operations Center in the U.S. at (404)676-6931 or toll free at 1(800)515-2022. Email: koc@coca-cola.com

29 October 13, 2016, Mohamad Khachab,

Managing Partner, ICS

THANK YOU

?

703-962-0793

khachabmy@ics4business.com http://www.ics4business.com/

linkedin.com/in/moekhachab