Adequate Procedures, Bribery Act & Proceeds of Crime - Written by Barry & Richard on Monday, May 13, 2013 1:42 - 0 Comments
Pure Gold: “A Compliance and Ethics Program on a Dollar a Day” by Joe Murphy
You’ve heard plenty about the red tape and unnecessary bureaucracy created by the Bribery Act.
Heard of Joe Murphy? Joe’s a fairly unassuming guy who will, if you ever meet him, tell you he likes dancing. Or at least that’s what he told me.
Joe’s written a short booklet “A Compliance & Ethics Program on a Dollar a Day”.
It’s worth the weight of a pallet load of them – in gold.
It’s free and published by the Society of Corporate Compliance and Ethics you can join this if you want for a nominal sum (US$295) but it’s not essential.
In the booklet you’ll find numerous ideas and specific recommendations for a compliance program for your business and from a very practical standpoint.
Barry met Joe on his recent visit to the G20 in Paris.
The booklet kills stone dead the constant refrain of those who complain about the unnecessary burden created by the Bribery Act.
The introduction, written by Roy Snell, Society of Corporate Compliance and Ethics, Health Care Compliance Association, begins:
“…I have listened to those who are reluctant to implement compliance programs complain for many years. I must admit, I am not sure I understand how you could oppose making an effort to follow the law and maintain an ethical culture. As is the case in many controversial issues in which someone’s position is weak or they have a limited grasp of the subject matter, they tend to exaggerate and make vague assertions/assumptions. In this case, those who are reluctant claim compliance programs are expensive.
…The claim that some companies—those that are small and medium sized—are too small to implement a compliance program is not accurate. Anyone with any business experience and who is being honest knows that any business operation can be managed efficiently or inefficiently. Compliance is no different. You can implement an effective compliance program with a small investment if you know what you are doing.”
Over the next few weeks we’ll extract some of our favourite tips. Below, we’ve embedded a copy of the booklet in this post.
In the meantime, how about three ideas, that will cost you NOTHING, from the book to get you started:
- Network with other companies, big and small. One great characteristic of the compliance and ethics field is that sharing is considered part of the profession. Whether it is a neighboring business, a supplier, or a customer, they may have their own compliance and ethics officer and useful materials they would share with you. You can contact the compliance and ethics officers at big companies you do business with (or want to impress) for copies of their materials. Feel free to ask others, but make sure each thing you get actually makes sense for your company. Cost: 0.
- Use groups where you are already a member. These may be trade industry associations, local chambers of commerce, or groups like Rotary. They provide opportunities for networking on compliance and ethics issues, and also a forum for outside speakers to provide information for free that is useful for your program. Cost: 0.
- Keep a record of everything you do as part of your program. Keep this in your computer—it’s not necessary to use paper printing it out. (But be sure you back-up your computer—if you are not already doing so, start today, not for compliance and ethics purposes but because your business could be at risk.) Cost: 0.
To those who complain about the difficulty of putting in place a decent compliance program without spending a fortune – the booklet is pure gold.
On the other hand, if you like complaining, bad luck. The booklet does not fit the narrative. Likewise if you find the Bribery Act and laws like it inconvenient because you believe it is necessary to pay bribes to do business – it won’t be any use at all.