Civil Engineering Reference
In-Depth Information
the business model, including interactions with associated persons. Some commer-
cial organizations may operate in a business sector that routinely offers hospitality as a
marketing tool and so are at risk of greater scrutiny. Businesses involved in export and
import will necessarily have greater exposure to and interaction with foreign officials,
leading to increased opportunities for breaches to occur. Each business model needs
to be assessed on its own merits, but each risk must be addressed to ensure compli-
ance with the legislation. It will be important for the organization to determine what
checks need to be made to assess the integrity of its business partners. he assessment
requirestobethoroughandreviewedonanongoingbasisasthebusinessdevelops
and new challenges are faced.
22.3.6 Due diligence
Duediligencewillalreadybeemployedinorganizationscommittedtogoodcorporate
governance, and the anti-bribery and corruption due diligence should fit firmly into
that framework. In line with the other principles, the response has to be proportionate
and risk-based. Due diligence is key where the organization uses associated persons
in its business model, and due diligence should be carried out on third parties.
22.3.7 Communication (including training)
This principle is focused on ensuring that policies and procedures are embedded in an
organization, and are widely understood. The intended benefits are enhanced aware-
ness of the risks of bribery as well as consolidation of the commitment to ensure
compliance. The Guidance points out that making 'information available assists in
more effective monitoring, evaluation and review' of bribery processes and proce-
dures. Training goes hand in hand with communication and serves as a means of
establishing an anti-bribery culture. Again the approach is focused on actual risks and
proportionality, advising that training should outline specific risks to specific posts,
sectors, functions, departments and locations. Effective training should be continu-
ous, monitored and evaluated to ensure compliance with the Bribery Act.
22.3.8 Monitoring and review
he monitoring and review of compliance procedures is necessary to ensure that they
are updated and reflect the risks and challenges the business faces on an ongoing basis.
Good monitoring should ensure internal control of the anti-bribery processes and
it is only where an effective monitoring function keeps track of bribery risk indica-
tors, sector-specific challenges, and other information arising from the processes or
training and performance of procedures and controls, that an organization will be able
to review processes to ensure that they are being regularly updated and reviewed.
The Guidance suggests that it might be appropriate to consider external veri-
fication, including independently verified anti-bribery standards maintained by
