ANTI-BRIBERY AND CORRUPTION PROGRAM
Commitment from the top of zero tolerance towards bribery or corruption
Draft and implement an Anti-Bribery and Corruption (ABC) policy
Develop detailed procedures and processes to compliment the ABC policy
Implement effective ABC internal controls and keep records of the controls performance
Invest in effective reporting mechanisms to detect bribery and corruption
Ensure effective oversight of the designed program
Educate and train all staff (from the executive down) on the ABC program
Adequately address breaches of the ABC program
Incentivise ethical behaviour
Regular reporting and insights to drive effective reviews
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