Wednesday, March 29, 2023
Tuesday, March 28, 2023
PENCERAMAH TIDAK BERTAULIAH TELAH DERHAKA PADA RAJA-RAJA
Sunday, March 26, 2023
MASALAH IBU TUNGGAL MENERIMA BANTUAN DARI GEREJA DAN DAKWAAN LEMBAGA ZAKAT TIDAK PERNAH MEMBERIKAN BANTUAN
QUOTE FOR THE DAY - BAILOUTS AND SHARES BUYBACK ARE NOT HELPING THE PEOPLE
When bailouts happen or corporate loans being approved with low interest rates and restructured, I think the money is intended to boost the economy by building more infrastructures and/or ease unemployment problems.
Friday, March 24, 2023
FINAL PART - ANTI BRIBERY MANAGEMENT SYSTEM - Nik Zafri
(ABMS = ISO 37001)
7.0 Continual Improvement
Nonconformity and corrective action
When a nonconformity (NC) occurs (usually issued via a Corrective Action Request (CAR), take quick action, control and correct.
Some NC can result in dire consequences such as OSH or Environmental issues that maybe fatal or cause damage to assets. Most safety issues are either related to ignorance or bribery. (Fatal dan Damage may be relevant to RISK MANAGEMENT, thus review the risk register to find out if the risk has been addressed and mitigated or the risk could be a new one)
(NC can sometimes repetitive in different places. It's advised that auditors should issue 1 CAR for same NC but state the occurrence at different locations)
Find out the root cause (s) of the NC. Root Cause is NOT a personal blaming platform. It should be more related to the process itself.
The idea of corrective action is not merely repairing the system or machine or devices, it is important to improve the process where similar NC may happen at other places as well. This is where preventive measures need to be taken which may include review of effectiveness and changes to the ABMS.
Corrective Action - shall be appropriate to the effects of non-conformities. Looking back at root cause and evidences may help in determining the right corrective action. It is imperative that auditors NOT to depend on pictorial evidence but to visit on a "before" and "after" the NC to verify the photos and action taken (including follow-up actions) accordingly by the auditee.
For auditors, the effectiveness of the corrective action can only be seen in the next audit. My advise that auditors should also look into the bribery risk register and relevant random inspection records where necessary. (in the next audit, the auditor should note the effectiveness of the last audited corrective action by looking into further evidence afterwards as well)
Continual improvement is to determine suitability, adequacy and effectiveness of the anti-bribery management system.
This improvement could be the follow up actions from :
a) Changes in statutory and legal requirements,
b) Results of the Management Review,
c) changes in the ABMS itself,
d) internally proposed
Saturday, March 04, 2023
ANTI-BRIBERY MANAGEMENT SYSTEM - PART 8 - Nik Zafri
(ABMS = ISO 37001)
6.0 Performance Evaluation
- Monitoring - what has been established, implemented, impose control (e.g. revision, issue, superseded etc)
- Measurement - assess (audit/inspection) on benchmark, target
- Analysis - statistics on e.g. department vs non-conformance, project vs non-conformance etc.
- Evaluation - against effectiveness of ABMS
a) What to be monitored/measured
b) Person responsible
c) Method with expected/actual results
d) timeframe/cut-off period
e) results of monitoring and measurement - analysed/evaluated (usually in Management Review)
f) reporting flow
Documented information required as evidence (records/forms/checklists duly filled)
Procedure is present for guide.
Internal audit is much the same clause as ISO 9000/14000/45000 etc. (differences are - anti-bribery details are defined in this clause)
- conduct at planned intervals (set a cut-off period/timeframe/frequency) e.g. every 6 months = 1 Internal Audit or every 1 fiscal year = 1 or 2 Internal Audit (1 every 6 months)
- to comply and conform to the law and ABMS - as far as is practicable to the organization (custom) - not all elements/criterions fit the organization (justify why such element are skipped with evidence)
- effectively implemented and maintained.
should there be many locations or projects/sites - then arrangement to be made by at least the HQ to be audited and - should there be many locations or projects/sites - then arrangement to be made by at least the HQ to be audited and 2-3 ongoing projects (sampling) of different nature/trades (sampling per 5 projects) (as the projects may have a different team members)
- define audit criteria and scope and select competent auditors,
- conduct audit with objectivity and impartiality - either independent function/management representative, the function (critical department/unit) involved in anti-bribery, 3rd party etc.
- report the audit - top management/governing body
- compliance and documented evidence
- audit program/results
Audit shall be reasonable, proportionate and risk based (well-balanced between the 3 aspects),
Procedures shall be referred to ascertain any suspected or actual bribery, violation of policy or ABMS, failure of business associates (including consultant, supplier, vendor, contractor, sub-contractor) determine weakness or improvement
No auditor shall audit his/her own work. (this include his own unit or department - it must be cross-department/unit)
Management review
Top management shall review ABMS at planned intervals (every 6 months - 1 Management Review (MRM) or every fiscal year - 1 or 2 MRMs), determine suitability/adequacy/effectiveness.
MRM to consider : previous MRM, changes in external/internal issues, performance - non-conformities/corrective actions, monitoring/measurement results, audit results, bribery reports,investigation, risks and mitigation and continual improvement (if any) as output. (If ABMS requires no improvement, then maintain it and don't repair it unnecessarily)
MRM results to be reported to governing body (if any) and retain documented information/evidence.
Governing body (if any) shall review the ABMS for further action (investigation) if any by anti-bribery compliance function. Anti-bribery compliance function shall assess to ensure that AMBS is adequate, implemented and effective including investigations/audit results to be reported to Governing body.
The organization may also use business associate (3rd party is recommended) to assist in the review. (This will usually happen when results are inadequate or found dissatisfactory due to lack of substantial evidence)
