Professional Documents
Culture Documents
integrity в компании
Aнар Каримов
партнёр
«ЭКВИТА»
Background
With over US$ 1 trillion paid in bribes each year, the consequences are
catastrophic.
ISO has developed a new standard to help organizations fight bribery and
promote an ethical business culture.
It is vital for companies operating in this market to identify and mitigate their
exposure to corruption risks as well as implement effective internal controls.
— direct and indirect bribery (e.g. a bribe offered or accepted through or by a third
party).
-
“Bribery”:
offering, promising, giving, accepting or soliciting of an undue advantage of any value
(which could be financial or non-financial) directly or indirectly and irrespective of
location(s), in violation of applicable laws as an inducement of reward for a person
acting or refraining from acting in relation to the performance of that person’s duties.
“Management system”:
set of interrelated or interacting elements of an organization to establish policies,
objectives and processes to achieve those objectives.
“Policy”:
intentions and direction of an organization, as formally expressed by its top
management or its governing body.
“Process”:
set of interrelated or interacting activities which transforms inputs into outputs.
“Top management”:
person or group of people who directs and controls an organization at the highest level.
Context of organization -1
1. Understanding the organization:
c) the nature, scale and complexity of the organization’s activities and operations;
e) the entities over which the organization has control and entities which exercise
control over the organization;
b) ensuring that the organization’s strategy and anti-bribery policy are aligned;
Note: These activities shall be carried out by top management if the organization
does not have a governing body.
Top management-1
2. Top Management’s Duties:
Top management shall have overall responsibility for the implementation of,
and compliance with, the anti-bribery management system.
Top management shall ensure that the responsibilities and authorities for
relevant roles are assigned and communicated within and throughout every
level of the organization.
Managers at every level shall be responsible for requiring that the anti-bribery
management system requirements are applied and complied with in their
department or function.
The governing body (if any), top management and all other personnel shall be
responsible for understanding, complying with and applying the anti-bribery
management system requirements, as they relate to their role in the
organization.
Anti-bribery policy
Top management must establish an anti-bribery policy that:
a) prohibits bribery;
b) requires compliance with anti-bribery laws that are applicable to the
organization;
c) is appropriate to the purpose of the organization;
d) provides a framework for setting, reviewing and achieving anti-bribery
objectives;
e) includes a commitment to satisfy anti-bribery management system
requirements;
f) encourages raising concerns in good faith, or on the basis of a reasonable
belief in confidence, without fear of reprisal;
g) includes a commitment to continual improvement of the anti-bribery
management system;
h) explains the authority and independence of the anti-bribery compliance
function;
i) explains the consequences of not complying with the anti-bribery policy, etc.
Anti-bribery
compliance function
I. Top management shall assign to an anti-bribery compliance function the authority for:
II. The anti-bribery compliance function shall be adequately resourced and assigned to
person(s) who have the appropriate competence, status, authority and independence.
III. The anti-bribery compliance function shall have direct and prompt access to the
governing body (if any) and top management in the event that any issue or concern needs
to be raised in relation to bribery or the anti-bribery management system.
STRATEGY
Code of Ethics
Code of Conduct
ABC Policy
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