Gifts and hospitality policies shall be included in any compliance program, that is undoubtedly true, that said, particularly for hospitality, some may be tempted to consider accepting an extra trip, a first class and or a suite upgrade as a minor issue. This is unacceptable. Bottom line. One of the few things one may be certain … Continue reading Hospitality and blackmailing; two sides of the same coin
A year after my first piece, I am guest writing again for the Ethical Boardroom, this time about the anti-bribery standard ISO 37001 and its pitfalls. You can read it here
Whistleblowers around the world still fear retaliation, it is not surprisingly, therefore, that most of them decide to stay anonymous. However, is omitting his own name enough? Probably not, at least for reports made via phone calls. Even without disclosing his name, anyone, while talking on the phone, may release a number of details which … Continue reading GDPR: How to anonymise or pseudonymise whistleblowers allegations
I recently came across this post where prof. Michael Johnston defined relying on political will ‘magic thinking’ (actually he extended the same reasoning to the civil society). Given my experience in high risk countries, I respectfully disagree with prof. Johnston. Whilst corruption is strictly connected to the human kind (it can happen everywhere and in … Continue reading Is Political Will Necessary to Fight Corruption? Yes!
A few months ago, the American DoJ issued its Evaluation of Corporate Compliance Programs. The French Anti-Corruption Authority did the same very recently (here the link). What I immediately noticed reading the two documents is that the ‘new’ ISO 37001 is not even mentioned…
In order to clarify some aspects surrounding due diligence, I decided to write down some of the most dangerous situation one may encounter in his business life. The list below refers to third parties. Introduced by a public official as it may represent an indirect bribe, Seems not to have sufficient staff and/or means to … Continue reading Anti-Corruption, Here When You Should Start Worrying
“Due Diligence results are not what we were hoping for. What should we do?” I have heard this question many many times as anti-corruption due diligence is getting extremely important these days. Answering is not an easy task since there are countless cases and possibilities to take into account and must be assessed on case … Continue reading Addressing (Possible) Business Partners Past Misconducts