1. Scope and context of the organization :
The scope of the management system and the plan and objectives associated with it should be designed and documented. The objectives should be listed and available for the management as well as for other internal stakeholders. The context of your anti-bribery management system needs to be developed considering the needs and expectations of interested parties, and the internal and external issues impacting your company.
2. Leadership :
There should be a leadership team to guide and communicate all the roles and responsibilities stakeholders must take. The leadership team should take responsibility for the outcomes as well.
3. Planning :
Proper and step-by-step planning should be designed and documented. The planning must include actions to minimize risk and / or take advantage of opportunities identified in the context of the organization and bribery risks.
4. Support :
To successfully implement and maintain the system, support in the form of resources and tools should be provided as needed.
5. Operations :
Controls must be prepared taking into account due diligence processes, financial controls, nonfinancial controls, implementing antibribery controls with business associates, antibribery commitments, procedures for receiving and administering gifts, donations, etc., raising concerns, and dealing with bribery.
6. Constant evaluation and subsequent improvement :
There should be enough resources and leadership spared to monitor the performance of the system and evaluate its effectiveness. As a consequence, the management system and results should improve.
