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Integrity Leadership Programs (ILP)
Integrity Culture Building (ICB)

2018 became a record year for international companies being sanctioned for breaches of Anti-Corruption breaches. Only to resolve cases involving breaches of the US Foreign Corrupt Practices act (FCPA), companies paid a record USD 2,89 billion. In addition, comes the lost reputation- and remediation costs.

Banks and financial institutions have experiences major scandals being targeted for involvement in international Bribery and Money Laundering transactions with allegedly criminal collusion by individuals of the organizations.    

A dysfunctional culture seems to breed the sort of scandals that top the headlines and is becoming a regular media issue for high attention. 

To promote an organizational Integrity Leadership and Culture that encourage ethical conduct and a commitment to the agreed Core Values and unique company Code of Conduct, the processes of implementing ILP and ICB must prove the impact of bad culture (Storytelling), learn how leadership can influence culture (Role Modeling), building ethical conduct through communications strategies (Spread the Message and Ethical messaging within all financial target communication) and tackle the specific barriers that might come to surface during the processes (Fine-Tune the effort).   

 

Processes:

  1. Status Analysis

  2. Storytelling – Knowledge sharing for BoD and Management

  3. Measuring program effectiveness - Integrity survey: Ethics@Work

  4. Target Setting and Communications

  5. Staff involvement

  6. Recruitment

  7. Objectives

  8. Verbal Role Modeling

  9. Action Role Modeling

  10. Performance Evaluations and Integrity Reward and Recognition System

Anti-Corruption and Anti-Money Laundering initiatives

Anti-Corruption processes

  1. Risk Analysis

  2. Policy and Guidelines

  3. Storytelling – Knowledge sharing

  4. Integrity Due Diligence/ Investigative and Enhanced Due Diligence

  5. Third Party Management/Vendors onboarding

  6. Training and e-Learning

  7. Internal controls

  8. Technology-Enabled Third-Party Due Diligence and Investigations (using AI)

  9. Whistleblowing

  10. Reporting

  11. Incident and dilemma handling

 

Anti-Money Laundering Initiatives

  1. Assistance in implementing the new Anti-Money Laundering legislation of October 15, 2018

  2. Gap Analysis

  3. Storytelling – Knowledge sharing

  4. Risk Analysis – Risk-based

  5. Policy and Guidelines

  6. Customer Due Diligence/KYC/Investigative and Enhanced Due Diligence

  7. Transactions and Customer Monitoring

  8. Suspecious Transactions investigations

  9. Reporting to FIU (EFE/ØKOKRIM)

  10. Training and e-Learning

 

When an incident/wrongdoing has occurred:

  • Facts Finding incl. Root Cause Analysis.

    • What is the company’s root cause analysis of the misconduct at issue? What systemic issues were identified?  Who in the company was involved in making the analysis? 

    • Has the company’s investigation been used to identify root causes, system vulnerabilities, and accountability lapses, including among supervisory manager and senior executives?  What has been the process for responding to investigative findings?  How high up in the company do investigative findings go?

  • Thorough analysis of causes of underlying conduct (i.e., a root cause analysis) and, where appropriate, remediation to address the root causes

  • Testing and Implementation of an effective compliance and ethics program, the criteria for which will be periodically updated and which may vary based on the size and resources of the organization

    • The company’s culture of compliance, including awareness among employees

    • The resources the company has dedicated to compliance

    • The quality and experience of the personnel involved in compliance, such that they can understand and identify the transactions and activities that pose a potential risk

    • The authority and independence of the compliance function

    • The effectiveness of the company’s risk assessment and the manner in which the company’s compliance program has been tailored based on that risk assessment

    • The compensation and promotion of the personnel

    • The auditing of the compliance program to assure its effectiveness; and

    • The reporting structure of any compliance personnel employed or contracted by the company

  • Appropriate discipline of employees, including those identified by the company as responsible for the misconduct, either through direct participation or failure in oversight, as well as those with supervisory authority over the area in which the criminal conduct occurred

  • Appropriate retention of business records, and prohibiting the improper destruction or deletion of business records, including prohibiting employees from using software that generates but does not appropriately retain business records or communications

  • If relevant; Voluntary Self-Disclosure to the authorities and follow-up Cooperation

  • Internal and external communication

 
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