Learn about best practice for due diligence, effective training and communications and monitoring and review to minimise ABC risks.
On 30th September 2020 Viviane Joynes, Managing Director of the EQS Group’s UK business, hosted the second part of a three-part webinar series Bribery Act 10th Anniversary – What we’ve learned so far, in partnership with the Forensic Risk Alliance (FRA). Viviane was joined by Jo Morgan, Director of Ethics and Compliance at BT and Charlie Patrick, Partner at Forensic Risk Alliance (FRA). Together our experts discussed the challenges and best practice regarding the final three of the six adequate procedures – due diligence, training and communications and monitoring and review.
This article summarises the useful learnings which came out of this discussion.
Monitoring and review
1st and 2nd level tests deliver most value: Charlie pointed out that 1st level testing offers the business real time feedback, and 2nd level testing is a good way to show the business the controls that are in place and how compliance is supporting and adding value to the business. 3rd level testing which is carried out by internal or external auditors will always be more of a lagging indicator.
Automate where possible: Testing can be extremely labour-intensive so any effective automation of 1st and 2nd level testing is advantageous.
Dashboards – effort must be proportional to the result: Everyone loves a dashboard however, often the resources needed to get the right inputs into dashboards are out of proportion to the value they deliver. Dashboards only make sense when they produce meaningful data and insights that should always tie back to the risks identified. While dashboards are very useful, Jo warned not to let them substitute having proper conversations with business units to identify where risks might be emerging.
Click here to listen to this webinar. You can also click here to listen to Part 1 on adequate procedures which took place on 17th September 2020, or read the overview here.