(Anti Bribery Management System = ISO 37001:2016)
4.0 Support
Support = Resources required to implement, maintain and improve ABMS.
Competence
a) Determine the competence of employees,
b) Education background, training and experience,
c) Possible additional training required?
d) Reasignment or 3rd party support?
e) Document them as evidence
(It's a good practice to run a background check/screening of person(s) holding significant positions having authority on approval of financial matters)
Employment Process
Procedure (s) required.
- employment regulations - to address the need to comply with ABMS Policy and System and action that will be taken against non-compliances
(Bribery; once proven; IS A CRIME! Report it to the authorities and immediate termination should be executed - There is no need for reminders or warnings or showcause/domestic inquiries, even industrial courts as this is not a disciplinary matter, it's a crime)
- employee should receive a copy of such policy/regulations. Conduct refresher training/briefing/inductions at the right intervals if necessary.
- just like a whistleblower, employee must also be equally protected in case reports of bribery or possible bribery or rejecting bribery - being lodged disregarding position or social status.
- investigations, risk assessments and; if necessary; due diligence to be made once reports are lodged, if necessary - declaration of assets,
The anti-bribery compliance declaration can stand alone or be a component of a broader compliance declaration process.
Awareness and training
Adequate training/workshops/inductions on ABMS are required - if possible, not only on the key staff but also throughout the organization. Contents of training to include :
a) ABMS overall awareness, policy, procedures, roles/responsibility/authority
b) need for compliance, risks and opportunities,
c) how to recognize, react, prevent potential or actual events of bribery and corruption.
d) aspects of communication,
e) scope of bribery/corruption to include internal and external parties,
(those involving service providers - the contractual requirements can add a clause on "Bribery and Corruption")
Retain documented information.
Communication
- internal and external
a) What, When, With Whom, How, Who to communicate on ABMS various issues.
b) Medium of communication to be used - although one language shall prevail in case of ambiguity - other translated versions should be in multiple languages accordingly)
c) ABMS Policy; apart from all staff; should also be communicated/extended to Service Providers as well.
Documented information
A must have - Policy, Objectives, Plans, Manual, Procedures, methodologies, checklist, relevant codes of practice etc.
The extent of documented information can differ from one organization to another depnding on size, scope of work, processes (complexity/interaction),
products and services, competency etc. A banking and financial institution may differ in scope to a construction company.
So, APPLY ONLY THE NEEDED DOCUMENTS, not everything - not hijacked from others - not copy and paste from others!
ABMS documented information can be retained separately or part of other systems - compliance, financial, commercial, audit etc.)
(My advice? separate them! Unless you know what to omit and what to add without overlapping)
Format (Creating/Updating)
- identification/description - title/date, author, approval, reference number, revision/issue number,
- hardcopies or electronic (online) (online versions may subject to a stricter audit - identifying the authorized users acess, authorized to make amendment (s), the approval parties, encryption, firewall etc.)
- review for adequacy at intervals.
Control of documented information
Control :
a) available for use, location and when to use
b) protected (confidentiality, unauthorized access, loss of integrity (printed version can be compromised in the long run)
b) distribute, access, retrieval and use
c) storage and preservation
d) retention and disposition.
Superseded documents; if retained; must be quarantined and not to be filed together with the active ones. Justification is required of why the superseded documents are kept. Among reasons for retaining is for future reference and may also serve as evidence in the court of law.
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