The anti-bribery and corruption compliance officer’s annual report. The independent monitoring and review procedures and processes adopted by the ABC officer must be standardized, uniform, relevant, and consistent with the enterprise-wide bribery and corruption risks management practices. Such monitoring and review procedures enable systemically aggregating the data and information to identify any patterns, themes, or trends of bribery and corruption that may indicate the overall weaknesses in the internal control system. ABC officer performs reviews and investigations and verifies the key information obtained and used as evidence.
The Anti-Bribery And Corruption Compliance Officer’s Annual Report
In addition to periodic bribery and corruption risk assessment conducted by ABC officer, the ABC officer carries out the independent regulatory compliance reviews, based on a relevant sample, of material and high-risk activities of the organization, where non-compliance of anti-bribery and corruption risks may have serious regulatory implications on the organization’s reputation, strategy, financial stability and standing in the sector.
The ABC officer reviews must, at a minimum, cover the areas like the awareness of anti-bribery and corruption regulatory requirements, and adequacy of compliance controls, with the actions required to fulfill the identified internal controls gaps.
The ABC officer decides the areas, processes, and frequency of regular compliance risk reports to line managers and senior management. Based on anti-bribery and corruption reports, the ABC officer must report to the anti-bribery committee and the board on the observations and findings with appropriate analyses of bribery and corruption risks in the organization.
These reports should be in a manner and formats that allow the committee and the board to clearly understand the regulatory compliance risks to which the organization is exposed and the adequacy of internal controls to manage the bribery and corruption risks. These reports must facilitate the board’s performance of its oversight responsibilities for managing the bribery and corruption-related risks. The board must review and determine the type, content, and frequency of anti-bribery and corruption reports to receive the necessary data points and information required to perform the supervisory role.
The anti-bribery and corruption reports, at minimum, must include:
The results of the anti-bribery and corruption compliance risk assessments, including the monitoring and review of internal controls, and highlighting significant changes in the bribery and corruption risk profile of the organization;
A summary of bribery and corruption-related incidents identified through the internal compliance reviews by ABC officer, internal audit department, external regulatory examinations and as reported by various functions and departments, and the deficiencies noted in the management of bribery and corruption risks;
An assessment of the financial and non-financial impacts of bribery and corruption incidents on the organization, including the penalties imposed by the regulators or any other relevant enforcement authority;
Bribery and corruption issues identified in any department of the organization and/or any member of the senior management, and the status of associated investigations being taken;
An update on the changing regulatory requirements related to anti-bribery and corruption for the organization and the plans to manage related compliance risks and issues through appropriate additional policies or procedures.
Recommendations of corrective actions to address the bribery and corruption incidents, including the disciplinary actions;
A record of corrective measures taken and an assessment of the adequacy and effectiveness of internal control measures;
Insights and observations regarding the compliance culture to manage the bribery and corruption risks that exist in the organization or in any specific department or process of the organization that may give rise to the risk of regulatory non-compliance.
Final Thoughts
Bribery and corruption are not only against our company values; they are also illegal and can result in fines and penalties, including imprisonment and reputational damage, for both the employee and the company.
Bribery is never tolerated at Principal. We will not seek to influence others, either directly or indirectly, by offering, paying, or receiving bribes or kickbacks, or by using any other method that is unethical, illegal, or detrimental to our reputation for honesty and integrity. Employees and company representatives are expected to decline any opportunity that would jeopardize our ethical principles and reputation. While some laws only apply to bribes paid to government officials (both domestic and foreign), this policy also applies to non-government business partners.
