The ABX of a Copenhagen Charter® Bribery, Fraud and Corruption (BFC)
Audit
The assessment of Copenhagen Charter on BFC is to identify
key points of BFC oversight and interaction and to provide reasonable assurance
for transparency, accountability and visibility in BRF compliance defined
tin the roadmap and framework.
An audit of compliance with UK Bribery
Act or Foreign Corrupt Practices Act (FCPA) policies, procedures, and
processes can be a discouraging task. First and foremost it requires a
structured methodology and approach. If a well-designed and practical
Roadmap and Framework is not used, then the company, the processes, the
internal audit and the managers will go around in circles.
BFC issues, clarified, fixed and resolved
Furthermore, the assessment requires skilled personnel, appropriate data
analytics, and the findings must be categorized in what issues need a
better understanding or change of the process or the need for an investigation.
The annual assessment then is classified as a BFC compliance program.
The BFC program can only be meaningful if the difference between a bribery
risk that is clarified, fixed and resolved early in the stage. When a
small BFC default gets coiled out of the manager's hands and right into
the greasy grasps of the oversight authorities, The SFO, Justice Department
or SEC you are just asking for more trouble. Alstom, Italian oil giant
Eni, Glaxo (GSK) are among the many companies who could have avoided massive
loss of reputation.
High profits attract scrutiny
More than 70 listed companies were currently involved in China's drive
for anti-corruption investigations in 2014. The companies are in all trades,
from energy, real estate, medico to finance sectors. The corruption investigations
then can reveal issues involving activities in capital markets, IPOs,
and other corporate findings.
One of the principal members of our BFC assessment team is a forensic
accounting expert and a regulatory compliance person. Both have the required
investigative skills to test the adequacy of financial controls against
reporting processes and reporting;
- accurately assess the most sensitive transactions: It's not always
hidden as gifts, travel, or entertainment expenses
- determine the related and potential Governance, risk and compliance
areas that may need to be reviewed
- Internal auditor managers are also a part of the team to discover
the intricacies of business and BFC risks.
Risk-based approach
BFC audits come in many different forms. However, the methodology first
must narrow the scope of the audit to those issues that warrant focus
on a particular high-risk geography, high-risk third party. Then the focus
moves to internal business units, third party, business partners, and
pre- and post-acquisition due diligence review id an acquisition or merger
is involved.
Business Intelligence and Analytics
Big data and business complexities in global companies can be intimidating
for the inexperienced. The complete volume of transactions, business units,
matrix organisations, product lines, market structures and the sheer number
of people involved require BI and data analytics of some quality.
The issue of multiple IT platforms that trail the same types of data in
various local formats in the geographical areas where BFC issues are rampant
is the area of concern. Our compliance professionals in Bangalore and
Mumbai have the experience to sort and match. The team can address large
amounts of unstructured data and large volumes of transactions and merge
it all into a single, manageable platform to identify the relationships,
trade and purchase patterns, and other irregularities.
On the 25th of March, we will conduct a briefing on Bribery and Corruption
issues for invite see: (http://copenhagencompliance.com/RoundtableInvite-DK-25March2015-Charter.pdf)
