final key elements of an effective iso 37001
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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
[email protected] 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.
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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.
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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: [email protected]
29 October 13, 2016, Mohamad Khachab,
Managing Partner, ICS
