For a leading extractives company, GoodCorporation developed a customised anti-bribery and corruption (ABC) handbook and assessment framework. This framework was then used as the basis for evaluation of the company’s operations in 11 countries worldwide. The handbook helped the company by setting out in detail the testing that would be undertaken to evidence the ABC procedure. The handbook also helped the internal audit team to conduct its own testing, with example interview questions and testing programmes.
The framework and handbook were piloted in year one. In subsequent years, GoodCorporation has undertaken on-site assessment visits in widely different subsidiaries worldwide. In each subsidiary, GoodCorporation assessors worked alongside representatives from both the head office and local compliance teams to implement a two-week programme of interviews alongside detailed document, book and record reviews.
Each subsidiary received a grade for each framework point. Preliminary results were presented to the local management team. This was followed by a more detailed report, presented initially to the subsidiary before going on to head office. The full report provides an overall assessment of the adequacy of procedures highlighting strengths and weaknesses, making recommendations for improvements and indicating where remedial actions are required to ensure best practice is in place.
Using the GoodCorporation Anti-Corruption Benchmark, the company was also able to measure the adequacy of its procedures by location and against other companies in the benchmark.
The level of focus and clarity on the issues summarised in your Anti-Bribery and Corruption Framework has made my task of implementing the recommendations much more straightforward.
Dan Silver, former Head of Ethical Conduct
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