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Interactive Benchmarking and Best Practices Panel: Anti-Corruption Compliance Must-Do's to Avoid the Most Costly Mistakes
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3rd Latin America Summit on Anti-Corruption
Interactive Benchmarking and Best Practices Panel: Anti-Corruption Compliance Must-Do's to Avoid the Most Costly
Mistakes
Alexandre da Cunha Serpa, CCEP, CFELatin America and Caribbean Regional Compliance
HeadAlcon Laboratories
Alexandre da Cunha Serpa, CCEP, CFEThe opinions herewith are those of the author and do not reflect those of, nor are supported by, his employer company
Isaac Asimov
1. A robot may not injure a human being or, through inaction, allow a human being to come to harm.
2. A robot must obey the orders given to it by human beings, except where such orders would conflict with the First Law.
3. A robot must protect its own existence as long as such protection does not conflict with the First or Second Laws.
http://cronicologoexisto.blogspot.com.br/2012/01/simplest-possible-code-of-conduct-for.html
Alexandre da Cunha Serpa, CCEP, CFEThe opinions herewith are those of the author and do not reflect those of, nor are supported by, his employer company
Benchmarking?Best Practices?
1. Can you trust the data source?2. Can you replicate the conditions?
3. Is your company equal to any other?4. Enron’s practices have already been
THE example of best practices
Alexandre da Cunha Serpa, CCEP, CFEThe opinions herewith are those of the author and do not reflect those of, nor are supported by, his employer company
CPI – Corruption Perception Index(http://cpi.transparency.org/cpi2012/)
vs Last years’ FCPA cases(http://www.sec.gov/spotlight/fcpa/fcpa-cases.shtml)
CPI = Corruption Rationalization Index?
Alexandre da Cunha Serpa, CCEP, CFEThe opinions herewith are those of the author and do not reflect those of, nor are supported by, his employer company
Want to have the best Anti-Corruption program?
Alexandre da Cunha Serpa, CCEP, CFEThe opinions herewith are those of the author and do not reflect those of, nor are supported by, his employer company
What is corruption?
Alexandre da Cunha Serpa, CCEP, CFEThe opinions herewith are those of the author and do not reflect those of, nor are supported by, his employer company
Wikipedia: CorruptionIn philosophical, theological, or moral discussions,
corruption is spiritual or moral impurity or deviation from an ideal. Corruption may include many activities
including bribery and embezzlement.
Government,… corruption occurs when an office-holder or other governmental employee acts in an official
capacity for his or her own personal gain.
3. Be SIMPLE about it
a) It starts with “how do you intend on tackling ‘CORRUPTION’ in one program?”
b) Isn’t it only ‘BRIBERY’?c) No 10,000 pages
d) is accounting more important than the business?....
Alexandre da Cunha Serpa, CCEP, CFEThe opinions herewith are those of the author and do not reflect those of, nor are supported by, his employer company
2. Grant proper OWNERSHIP
a) No point having your Legal and/ or Compliance department being the ones to review contracts/ approve transactions
Alexandre da Cunha Serpa, CCEP, CFEThe opinions herewith are those of the author and do not reflect those of, nor are supported by, his employer company
1. Be SERIOUS about it
a) Sanctions shall be strongb) ALL people/ actions/ words have to be an example
b.1) “Don’t cry like a ….” b.2) Briefcase bearer
b.3) Enron’s CFO b.4) “But he is a good salesman…”
b.5) I don’t care losing ….
Actually “b” is THE ONE thing that is important always and will make or break your programs
Alexandre da Cunha Serpa, CCEP, CFEThe opinions herewith are those of the author and do not reflect those of, nor are supported by, his employer company
Is that ALL?
Of course not, but those are the MUST DO’s ……And, in my opinion, 95% of “all” ……
Alexandre da Cunha Serpa, CCEP, CFEThe opinions herewith are those of the author and do not reflect those of, nor are supported by, his employer company
?Alexandre da Cunha Serpa, CCEP, CFEThe opinions herewith are those of the author and do not reflect those of, nor are supported by, his employer company
Contacts:[email protected]
[email protected]://br.linkedin.com/in/alexandreserpa
ObrigadoThank you
Gracias
