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Foreign Corrupt Practices Act of 1977
         UK Anti-Bribery Act
Introduction

• In spite of some broad and some minor differences
  between the FCPA and the UK Bribery Act, there is a
  wide overlap between the two sets of requirements
• Firms can ease the management and review of
  their obligations using the easy2comply Risk
  Management software
Software Focus

• The easy2comply software is focused on these
  areas:
  1. Corruption and Bribery Risk Assessment
  2. Internal Control Monitoring
  3. Policy Dissemination and Sign Off
  4. Incident Management
  5. Anonymous Whistleblowing
• The following slides will take you through each
  point
Corruption and Bribery Risk Assessment



                                         4
Corruption and Bribery Risk Assessment

• Create a “map” of your company
• Focus on troublesome areas such as:
  – Third parties
  – Known countries
  – Agents
• Identify potential risks
• Assess risks based on:
  – Severity / Likelihood
  – Customised Scorecards
Business Structure

      • No limitation to hierarchy
      • Create easy visual
        representation of business
        model
      • Simple user access model
        ensuring people can only
        see / edit what they are
        allowed to
Risk Profiling (Scorecards)




• Flexible scorecards – build your own question sets,
  answers and scoring methodology
• Ensures consistency and standardisation
Specific Risk Identification and Assessment




• Add your own risks
• See risks listed neatly and concisely
• Each risk can be explored for a much richer analysis
Clear Risk Documentation
Risk Assessment




• Impact and Likelihood assessment
• Residual Risk based on implemented controls
• Different methodologies available
Benefits of Risk Assessment

• Easily identify based on risk assessment where
  the most problematic areas are
• Share Risk Assessments with people from
  across the company, no matter where they are
• Generate charts and Excel reports
Internal Control Monitoring



                              12
Internal Control Monitoring

• Build dynamic library of controls
• Assign responsibilities for checking the
  controls
• Document evidence on frequent basis
• Attach files and documents as part of
  information gathering process
Control Libraries




• Add your own controls
• See who checked them and when
• See when they are next due for testing
Control Documentation
Create a Test Plan
Document Findings and Recommendations
Upload Attachments as Evidence
Easy Reporting
Benefits of Internal Control Monitoring

• All data is time-stamped and user-stamped,
  ensuring full traceability and auditability
• People can work in parallel
• Evidence uploaded directly into the software
• Makes it very easy to demonstrate that there
  is a proper and formal process to manage
  controls
• Automated notifications and alerts
• Simple reporting and charting
Policy Dissemination and Sign Off



                                    21
Policy Review
Track the Policy Team
Management Signatures




• Track who has signed off on the policy in real time
• Monitor those that haven’t signed
• Creates a digital signature
Policy Sign Off Benefits

• Proof that management have seen and
  reviewed the policy
• Track who has signed and who hasn’t
• Include questionnaires (if desired) to ensure
  the policy is understood
Incident Management



                      26
Incident Management

• Identify new and old incidents relating to
  fraud and corruption
• Track the investigation and remediation
  process
• Demonstrate to officials that there was clear
  ownership and accountability from the
  moment the issue was identified
Incident Database




• Build database of fraud and corruption related
  events and incidents
• Filter by location, business and date
Document the Incident
Draw Conclusions and Recommendations
Incident Management Benefits

• Anywhere in the world, incidents can be
  created and entered into the database
• Document proof that necessary steps and
  measures were taken
• Build a library of lessons that can be learnt
  and shared with other business groups
Anonymous Whistleblowing



                           32
Anonymous Whistleblowing

• Anyone can record a “potential event” relating
  to fraud, bribery and corruption
• Registrants do not need to log in to a software
  nor do they need to provide their details
• All whistleblowing events will be distributed to
  a pre-determined group within the company
  for further analysis
Where do I record the Event?

• Application homepage
• No need to log in to the
  software
• Page can be added to
  client corporate intranet
  page as well
What do they fill in?

• Fully configurable
  form
• Fields determined
  by company
• Default form can
  be seen here
Anonymous Whistleblowing Benefits

• Allows all individuals and employees peace of
  mind when recording incidents
• Company can track potential events as they
  are identified
• Prove to regulator that best efforts were made
  to provide a safe space for the reporting of
  events
For more information on the UK Bribery Act or Foreign
Corrupt Practices Act, please contact:

Jeremy Kaye jeremy.kaye@easy2comply.com
Sales       sales@easy2comply.com
                                                        37

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Foreign Corrupt Practices Act of 1977 UK Anti-Bribery Act

  • 1. Discover why 50,000 professionals have already switched to easy2comply Foreign Corrupt Practices Act of 1977 UK Anti-Bribery Act
  • 2. Introduction • In spite of some broad and some minor differences between the FCPA and the UK Bribery Act, there is a wide overlap between the two sets of requirements • Firms can ease the management and review of their obligations using the easy2comply Risk Management software
  • 3. Software Focus • The easy2comply software is focused on these areas: 1. Corruption and Bribery Risk Assessment 2. Internal Control Monitoring 3. Policy Dissemination and Sign Off 4. Incident Management 5. Anonymous Whistleblowing • The following slides will take you through each point
  • 4. Corruption and Bribery Risk Assessment 4
  • 5. Corruption and Bribery Risk Assessment • Create a “map” of your company • Focus on troublesome areas such as: – Third parties – Known countries – Agents • Identify potential risks • Assess risks based on: – Severity / Likelihood – Customised Scorecards
  • 6. Business Structure • No limitation to hierarchy • Create easy visual representation of business model • Simple user access model ensuring people can only see / edit what they are allowed to
  • 7. Risk Profiling (Scorecards) • Flexible scorecards – build your own question sets, answers and scoring methodology • Ensures consistency and standardisation
  • 8. Specific Risk Identification and Assessment • Add your own risks • See risks listed neatly and concisely • Each risk can be explored for a much richer analysis
  • 10. Risk Assessment • Impact and Likelihood assessment • Residual Risk based on implemented controls • Different methodologies available
  • 11. Benefits of Risk Assessment • Easily identify based on risk assessment where the most problematic areas are • Share Risk Assessments with people from across the company, no matter where they are • Generate charts and Excel reports
  • 13. Internal Control Monitoring • Build dynamic library of controls • Assign responsibilities for checking the controls • Document evidence on frequent basis • Attach files and documents as part of information gathering process
  • 14. Control Libraries • Add your own controls • See who checked them and when • See when they are next due for testing
  • 17. Document Findings and Recommendations
  • 20. Benefits of Internal Control Monitoring • All data is time-stamped and user-stamped, ensuring full traceability and auditability • People can work in parallel • Evidence uploaded directly into the software • Makes it very easy to demonstrate that there is a proper and formal process to manage controls • Automated notifications and alerts • Simple reporting and charting
  • 24. Management Signatures • Track who has signed off on the policy in real time • Monitor those that haven’t signed • Creates a digital signature
  • 25. Policy Sign Off Benefits • Proof that management have seen and reviewed the policy • Track who has signed and who hasn’t • Include questionnaires (if desired) to ensure the policy is understood
  • 27. Incident Management • Identify new and old incidents relating to fraud and corruption • Track the investigation and remediation process • Demonstrate to officials that there was clear ownership and accountability from the moment the issue was identified
  • 28. Incident Database • Build database of fraud and corruption related events and incidents • Filter by location, business and date
  • 30. Draw Conclusions and Recommendations
  • 31. Incident Management Benefits • Anywhere in the world, incidents can be created and entered into the database • Document proof that necessary steps and measures were taken • Build a library of lessons that can be learnt and shared with other business groups
  • 33. Anonymous Whistleblowing • Anyone can record a “potential event” relating to fraud, bribery and corruption • Registrants do not need to log in to a software nor do they need to provide their details • All whistleblowing events will be distributed to a pre-determined group within the company for further analysis
  • 34. Where do I record the Event? • Application homepage • No need to log in to the software • Page can be added to client corporate intranet page as well
  • 35. What do they fill in? • Fully configurable form • Fields determined by company • Default form can be seen here
  • 36. Anonymous Whistleblowing Benefits • Allows all individuals and employees peace of mind when recording incidents • Company can track potential events as they are identified • Prove to regulator that best efforts were made to provide a safe space for the reporting of events
  • 37. For more information on the UK Bribery Act or Foreign Corrupt Practices Act, please contact: Jeremy Kaye jeremy.kaye@easy2comply.com Sales sales@easy2comply.com 37