This document discusses key elements of an effective anti-bribery management system according to ISO 37001. It defines ISO 37001 as an anti-bribery management standard to help organizations establish, implement, maintain, and improve anti-bribery compliance programs. It also provides examples of Morgan Stanley's anti-bribery best practices and discusses the role of education, training, culture, and technology in preventing bribery.

1. Key Elements of an effective
Anti-Bribery Management
System ISO 37001
Implementation
1October 13, 2016, Mohamad Khachab, Managing Partner, ICS

2. Mohamad Khachab
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3. Definition ISO 37001
ISO 37001 is an anti-bribery management
system standard designed to help an
organization establish, implement, maintain,
and improve an anti-bribery compliance
program or “management system.”
3October 13, 2016, Mohamad Khachab, Managing Partner, ICS

4. • Is Bribery still common in the workplace today?
Private sector? Public Sector?
• Do you have a compliance program? Is it defensible?
• Can you demonstrate your compliance to your board?
Government (s) ? Regulatory bodies?
• How about your agents?
• Are you monitoring proactively? How you handle
exceptions?
• Do you analyze your expenditures?
• Can you identify patterns of improper behavior or
collusion?
• Have you done enough training and education?
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October 13, 2016, Mohamad Khachab,
Managing Partner, ICS

5. 5
October 13, 2016, Mohamad Khachab,
Managing Partner, ICS

6. Morgan Stanley can serve as a model for any
organization to follow as a best practice:
• Document everything
• Conduct regular program auditing
• Educate employees
• Implement global financial systems controls
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October 13, 2016, Mohamad Khachab,
Managing Partner, ICS

7. The Private Sector has a central role to play in preventing
detecting and responding to bribery in int’l business.
In 2009, the OECD and the Working Group on Bribery
released good practice guidance on internal controls,
ethics, and compliance.
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October 13, 2016, Mohamad Khachab,
Managing Partner, ICS

8. 8
October 13, 2016, Mohamad Khachab,
Managing Partner, ICS

9. 9
October 13, 2016, Mohamad Khachab,
Managing Partner, ICS

10. A-B
Argentina
Australia
Austria
Belgium
Brazil
Bulgaria
C-F
Canada
Chile
Colombia
Czech Republic
Denmark
Estonia
Finland
France
G-K
Germany
Greece
Hungary
Iceland
Ireland
Israel
Italy
Japan
Korea
L-R
Latvia
Luxembourg
Mexico
Netherlands
New Zealand
Norway
Poland
Portugal
Russia
S-Z
Slovak Republic
Slovenia
South Africa
Spain
Sweden
Switzerland
Turkey
United Kingdom
United States
http://www.oecd.org/daf/anti-bribery/countryreportsontheimplementationoftheoecdanti-briberyconvention.htm
Country reports on the implementation of the
OECD Anti-Bribery Convention
Every country that is party to the Anti-bribery Convention has an interest in
ensuring that all parties live up to their obligations. Country monitoring reports
contain recommendations formed from rigorous peer-review examinations of
each country. These country monitoring reports and implementation efforts can
be accessed below.
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October 13, 2016, Mohamad Khachab,
Managing Partner, ICS

11. Estonia in a Nutshell in 2014
• 29 individuals and 15 entities were sanctioned under criminal proceedings for foreign
bribery in 2014.
• At least 10 of the sanctioned individuals were sentenced to prison for foreign bribery.
• At least 16 individuals and 15 entities (mainly companies) have been sanctioned in
criminal, administrative and civil cases for other offences related to foreign bribery,
such as money laundering or accounting misconduct, in 8 Parties.
• 361 individuals and 126 entities have been sanctioned under criminal proceedings for
foreign bribery in 17 Parties between the time the convention entered into force in
1999 and the end of 2014.
• At least 95 of the sanctioned individuals were sentenced to prison for foreign bribery.
• At least 110 individuals and 200 entities have been sanctioned in criminal,
administrative and civil cases for other offences related to foreign bribery, such as
money-laundering or accounting, in 8 Parties.
• Approximately 393 investigations are ongoing in 25 Parties to the Anti-Bribery
Convention.
• Prosecutions are ongoing against 142 individuals and 14 entities in 12 Parties for
offences under the Convention.
11October 13, 2016, Mohamad Khachab, Managing Partner, ICS

12. John Verver, CPA, CISA, CMC WWW.acl.com
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October 13, 2016, Mohamad Khachab, Managing Partner, ICS

13. 13
October 13, 2016, Mohamad Khachab,
Managing Partner, ICS

14. 14
October 13, 2016, Mohamad Khachab,
Managing Partner, ICS

15. Code of Business
Conduct Anti-Bribery
Policy
Anti-Corruption
Toolkit
Risk
Mapping
Risk
Assessment Partnerships
CULTURE
Reporting &
Documentation
Globalization
Education & Training
ISO 37001
Monitoring &
Testing
Commitment
Resources /
Know-How
Control
Environment
Ethics
Internal Audit
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October 13, 2016, Mohamad Khachab,
Managing Partner, ICS

16. You need to implement a plan
Earn/Guarantee senior level support for your plan,
budget, needed dedicated resources.
Keep them informed.
PMO to manage the project, documents, and
deliverables.
Increase awareness within organization and with
stakeholders.
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October 13, 2016, Mohamad Khachab,
Managing Partner, ICS

17. Culture
• Be diligent in your efforts to promote an
ethical culture and ensure that people work
within the confines of the rules.
• People go to work with a core function; are
hired to do a job.
• People face dilemmas on jobs, and are
supposed to make decisions.
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October 13, 2016, Mohamad Khachab,
Managing Partner, ICS

18. Ethics Office
• Every government agency or private
organization should have an ethics office and
every ethics office shall be staffed with ethics
officials.
• These individuals shall be available every day
to answer questions related to standards of
conduct in a confidential secure fashion.
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October 13, 2016, Mohamad Khachab,
Managing Partner, ICS

19. Training
• Increased need reported.
• Annual training must be given to all
employees who hold positions of significant
responsibility or authority.
• Annual required verbal training for public
filers each calendar year.
• Agencies are encouraged to vary the content
of verbal training from year to year but the
training must include, at least, a review of the
following items:
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October 13, 2016, Mohamad Khachab,
Managing Partner, ICS

20. Training - 2
(1) General principles for ethical conduct
(2) The Standards of conduct
(3) Any supplemental standards;
(4) Conflict of interest statutes; and
(5) Contact information of persons / advisors on
ethics issues.
Employees must be given at least one hour of
official duty time for verbal training.
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October 13, 2016, Mohamad Khachab,
Managing Partner, ICS

21. Training - 3
The training must be:
(1) Presented by a qualified instructor; or
(2) Prepared by a qualified instructor and presented
either in-class, web-based, or thru videotape.
• If the training is prepared by a qualified instructor
and presented in non-classroom setting, a
qualified instructor must be available during and
immediately after the training to answer
questions.
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October 13, 2016, Mohamad Khachab,
Managing Partner, ICS

22. Education
• Education is foundation of any ethics
program. It must be visible, consistent, and
flexible.
• Assess the education needs of your ethics
officials by administering an annual training
needs assessment questionnaire and
collecting post-training evaluation data.
• Training must be the central part of your
ethics program
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October 13, 2016, Mohamad Khachab,
Managing Partner, ICS

23. Customization
Customization of education and training allow
employees to learn in the context of their
agency or job and this is important to ensure
that people actually process the information
given to them and feel equipped to deal with
challenges as they arise.
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October 13, 2016, Mohamad Khachab,
Managing Partner, ICS

24. Awards / Reinforcement Program
• Develop an awards program to allow your
organization to use positive reinforcement to
encourage offices/branches to focus on
education.
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October 13, 2016, Mohamad Khachab,
Managing Partner, ICS

25. MEDIA
• Use media intelligently.
• Send a strong message.
• Use posters to send message. Post them
strategically. They are quick and very
economic to produce and can be customized
to treat specific issues at specific locations.
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October 13, 2016, Mohamad Khachab,
Managing Partner, ICS

26. Technology
The days where auditing a selected sample of few
transactions is long gone. Today regulators require
organizations to install comprehensive monitoring tools to
mitigate risk especially for those organizations that
work in multi-international/national environments.
Awareness raising activities highlight the benefits of
compliance, including potentially saving the company from
both the risk of bribery and the costs Involved in exposure
and sanctioning.
Today’s boards have to be aware of environment,
standards, new trends, technological factors, and risk(s).
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October 13, 2016, Mohamad Khachab,
Managing Partner, ICS

27. 27
October 13, 2016, Mohamad Khachab,
Managing Partner, ICS

28. 28
October 13, 2016, Mohamad Khachab,
Managing Partner, ICS

29. Welcome to EthicsLine
EthicsLine is a reporting service offered by The Coca-Cola Company and administered
by a third party, Global Compliance.
•You may access EthicsLine by telephone or on this website.Telephone
Call toll free at 1(866)790-5579 in the United States and Canada, or go to the list of toll
free international access codes.
•Online
To get started, we need some basic information from you.
1. Where are you located?
2. Where did the event you are contacting us about take place?
Click "continue" to proceed.
Continue
Issues Concerning Immediate Violence or Threat
Contact the Strategic Security KO Operations Center in the U.S. at (404)676-6931 or toll
free at 1(800)515-2022.
Email: koc@coca-cola.com
29
October 13, 2016, Mohamad Khachab,
Managing Partner, ICS

30. THANK YOU
?
703-962-0793
khachabmy@ics4business.com http://www.ics4business.com/
linkedin.com/in/moekhachab