Transparency International - USA Toolkit
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TI -USAToolkit Table of Contents

I) Does a Company size make a difference?

A.) Laws and Authorities

B.) Case Summaries

C.) Metcalf Case Summary

D.) Bibiliography of General Sources.

II) Key Elements of an Anti-Corruption Compliance Program

A.) High Level Leadership/ Oversight

Caremark Case Study (PDF)

B.) Risk Assesment

Buiding a Company Profile (PDF)

Manager Guide (PDF)

C.)Written Standards /Policies

Sample Policies

Sample Proceedures

D.) Reporting Mechanisms

Guidelines for Reporting & Handling Principles & Policy Statements Concerns (PDF)

E.) Training & Education

Sample Training Materials

On-line Training Services

F.) Internal Controls & Recordkeeping

G.) Program Audit

Audit Guidelines (PDF)

Compliance Review (PDF)

H.)Respomnding to Potenetial Problems

Investigations & Remedial Action (PDF)

Sample CEO Letter

Sample General Counsel Letter (PDF)

III) Overcoming Resistance/Inertia

A.) Ethics Program Overview (PDF)

B) Bibliography of General Sources

 

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Transparency International-USA

Toolkit

B.    Risk Assessment: 

To be effective, a compliance program should not be imposed on a company’s existing structure and culture, but rather should grow out of that structure and culture.  A program that is properly harmonized with a company’s unique culture, risk profile, and existing operational mechanisms will more quickly be absorbed into a company’s day-to-day operations as a natural part of doing business, which is the hallmark of the most effective compliance programs.  To achieve this result, the first step in designing the program is to perform what is commonly referred to as a risk assessment.  The risk assessment can also be thought of as a company compliance profile  it brings together the factors that inform choices in program design, such as company management style, geographic scope, size, and product characteristics.  Without such a profile in mind at the outset, it will be very difficult to design a program that has a strong likelihood of success in any company.

See Risk Assessment: Building A Company Profile Manager’s Guide for guidance in developing a checklist or compliance program questionnaire.