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EXAMPLE: 3 YEARS AUDIT PROGRAM
them
achieve
to
Schedule & 3 YEARS
Program Organizational roles, responsibilities and authorities Implementation of anti-bribery controls by controlled AUDIT
Context of the organization stakeholders Management System Anti-bribery Management System Bribery risk assessment Leadership and commitment Anti-bribery Competence Awareness and Training Communication Documented Information Operational planning and control Due Diligence Financial controls Non-financial controls organizations Anti-bribery commitments Raising Concerns Performance evaluation Internal Audit Management Review Improvement Nonconformity and corrective action Continual improvement
ABMS Understanding the organization and its context Understanding the needs and expectations of Determining the scope of the Anti-Bribery Actions to address risks and opportunities objetives and planning Gifts, hospitality, donations and similar benefits Managing inadequacy of anti-bribery controls Investigating and dealing with bribery Monitoring, measurement, analysis and evaluation Review by anti-bribery compliance function PROGRAM
Resources
Support
Process/Clause 4 4.1 4.2 4.3 4.4 4.5 5 Leadership 5.1 5.2 Policy 5.3 6 Planning 6.1 6.2 7 7.1 7.2 7.3 7.4 7.5 8 Operation 8.1 8.2 8.3 8.4 8.5 8.6 8.7 8.8 8.9 8.1 9 9.1 9.2 9.3 9.4 10 10.1 10.2 Year 1 Year 2 Year 3
0
Managemen Human X X X X X X X X X X X X X X X X X X
t Management
Managemen Integrity X X X X X X X X X X X X X X X X X X
t
Purchasing X X X
Purchasing X X X X X X X X X X X X X X
management
Project X X X
Project X X X X X X X X X X X X X X X
Management
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