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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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