P1：Bribery and Corruption（2）

ACCA P1考試：Bribery and Corruption

4.6.5 Communication and Training

Bribery prevention policies and procedures are embedded and understood throughout the organisation through internal and external communication (including training) which is proportionate to the risks the organisation faces.

Making information available (communication) assists in more effective monitoring, evaluation and review of bribery prevention procedures.

Training provides the knowledge and skills needed to employ the organisation's procedures and deal with any briberyrelated problems or issues which may arise.

Apart from conveying the "tone at the top" and the implementation of policies and procedures, internal communication must include a secure, confidential and accessible means for internal or external parties to raise concerns about bribery (whistle-blowing or "speak up") provide suggestions for improvement of bribery prevention procedures and controls for requesting advice.

External communication will include:

Publication (e.g. on an organisation's website) of its code of conduct in relation to bribery and its bribery prevention procedures, controls, sanctions, results of internal surveys, rules governing recruitment, procurement and tendering

Similar details in the organisation's annual CSR report.

Even if the risk of bribery is low, some general training on bribery prevention would still be appropriate.

All induction for new employees, directors and associated persons must include bribery prevention.

For those in higher-risk areas (e.g. procurement, marketing, sales, associated persons—agents, contractors, etc) and the maintenance of the "speak up" channels, specifically tailored training programmes should be used.

To be effective, training must be continuous and regularly monitored and evaluated.

4.6.6 Monitoring and Review

Procedures designed to prevent bribery by persons associated with the organisation must be monitored and reviewed and improvements made where necessary.

Organisations operate in open and dynamic environments and, as with any risk, bribery risk will evolve and change. Controls currently in place may become ineffective and need to evolve to effectively mitigate risks. New training procedures may be needed.

Feedback from training, staff surveys and questionnaires, "speak up" feedback and known control breakdowns provide an important source of information.

Internal audit and external bribery and corruption reviews (conducted by appropriately qualified and experienced bodies) and assurance are additional sources of review.*

*Organisations which apply good corporate governance will, most likely, have incorporated all of the Bribery Act principles as standard practice.