UKBA - BS 10500 Demonstrate Good Governance Demonstrate Good Governance Chris Pascoe
UK Bribery Act (UKBA) UKBA Organisations must demonstrate that adequate procedures are (and if investigated, were) in place – a UKBA defence. defence. BS 10500 Clearly defines & specifies the components of an Anti Bribery Policy and Anti Bribery Management System (ABMS), in order to demonstrate Best Practice in accordance with the UKBA.
Requirements Communicate Communicate policies and procedures to all stakeholders …or why create them in the first place? Comply Ensure that all stakeholders read the policies and make a compliance declaration within a defined period Record Record Maintain records of all personnel who have received the policy; made a compliance declaration; and most importantly, those that have not Educate Provide and repeat appropriate education where necessary Review Review the ABMS on (at least ) an annual basis
Communication is key How would/do you do this to comply? Not just for UKBA/BS 10500 but for all key policies and procedures? Email Intranet/ SharePoint In person Traditional methods of communication are no longer adequate
Using traditional methods: How would you ensure (and prove) that individual stakeholders did receive, read, understand and agree to abide by particular policies? When required to do so, could you provide the version of the policy that individual stakeholders received at the time? – not policy that individual stakeholders received at the time? – not the version that is in force now! How would you manage joiners, movers and leavers? How would you ensure that the ABMS was reviewed annually?
Proactive Policy Management Many of our Customers have addressed these issues, and more, by deploying PolicyHub , a built-for-purpose Policy Management solution .
Just a few Clients
Customer feedback Işbank Benefits highlighted by Işbank Consistent, centralised management of policies and procedures – UKBA, Anti- Fraud, AML “I would recommend this product to all “Hitec have a thorough understanding of the “Hitec have a thorough understanding of the “The reporting we can now quickly and easily “The reporting we can now quickly and easily A compliance audit trail to prove staff A compliance audit trail to prove staff organisations, it makes Policy and Procedure organisations, it makes Policy and Procedure Banking Sector and the challenges a regulated keep up-to-date with changes in policy generate is just so powerful and the ROI is management simple and takes the headache business faces.” incremental - I find new ways to utilise Reduced administration leading to out of management and regulatory reporting. PolicyHub everyday, increasing efficiency at immediate time and cost savings It quickly becomes a tool that you wonder how every stage” Flexible assessment module you lived without” Detailed reporting Robert Wood, Operations Manager & MLRO, Işbank. Demonstrable evidence of best practice and good governance
Customer feedback - ALD Automotive (Societe Generale) Benefits Highlighted by ALD Immediate time and cost savings Demonstrable good governance for the board (Code of Conduct, AML) AML) ”In less than a week, we had secured “For policy owners, we’re providing immediate “At Group level Societe Generale can Ability to re-brand to fit agreement to key policies from over 80% of EVIDENCE of how and when policies are being demonstrate excellent Corporate Governance corporate brand guidelines staff. ….. At a Group level, we are accepted” and Compliance” demonstrating an excellent level of corporate Simplified process for staff who are more aware of governance and compliance” responsibilities Lindsay Grant, Business Services Management, Complete visibility of ALD Automotive compliance
Customer feedback – Morgan Cole Benefits Highlighted by Morgan Cole Ability to rigorously enforce a policy within a deadline Ensured policy UNDERSTANDING Conflict of interests & declarations; “We had well written policies and a system “We’re seeing benefits from using Corporate Governance “Compared to the previous approach to of policy “owners” – we were struggling of policy “owners” – we were struggling PolicyHub on multiple fronts – delivering PolicyHub on multiple fronts – delivering communicating and tracking policies, we Compliance audit trail proving with a lack of a system to make this process compliance cost savings and highest levels of cut on going management costs by a ratio really effective, simple and sustainable” operational effectiveness” of 20:1…… shortening the policy High levels of staff understanding acceptance cycle…… a 24:1 improvement” Detailed reporting, Lexcel Law Society Quality Standards adherence In tenders, ability to demonstrate Jeff Wright, I&T Director, Morgan Cole. highest levels of process Costs cut by 20:1
Customer feedback Associated British Foods - AB Agri Benefits highlighted by AB Agri Audit trail of policy communication and agreement (or not!) Visible evidence of staff awareness “We started thinking PolicyHub could help of essential policies – Fraud, with IT Security Policies – but quickly with IT Security Policies – but quickly “Information Security policies such as “Information Security policies such as Whistleblowing, Acceptable Use Whistleblowing, Acceptable Use established it could transform effectiveness Acceptable Use for email and internet and many others of SO many policies, from HR, employee benefitted by PolicyHub’s ability to check Ability to immediately keep remote staff questionnaires through to essential employee policy status and immediately up to date procedures that support business present policies for agreement” operations.” Ability to rapidly respond to national programmes (e.g. Avian Flu) Martin Freeman, IS Security Services Manager, AB Agri Ability to be sure of meeting rigorous Compliance, Business Ethics, and Security obligations
PolicyHub Step 1: Step 2: Create, import, amend Internal review process Policies Step 6: Step 3: Audit every action Publish the right policies and in-action to the right people Step 5: Step 4: Ensure understanding of key policies Employee affirmation for key policies
PolicyHub Benefits ensures the key policies and procedures get to the right people ensures the key policies and procedures get to the right people that their knowledge is assessed they become accountable by signing up to them that the entire process is recorded and auditable provides demonstrable evidence of BS10500 policy communication shows proof of staff “compliance statement” shows proof of “adequate procedures” being in place - a UKBA defence
Questions & Contact Details Chris Pascoe Chris.pascoe@hiteclabs.com UK Headquarters Tel: 01628 600900 Hitec Laboratories Ltd Specialising in the development, 430 Bath Road implementation and support of Slough Policy Management; Enterprise Content; Berkshire Risk and Compliance management SL1 6BB solutions. Over 350 customers in more than 40 www.hiteclabs.com Countries
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