7.2.2.2 - Procedures for high-risk positions

How to Answer the Question

To effectively implement necessary procedures for high-risk positions, organizations should follow these guidelines:

1.   Risk Assessment  :

  -   Identify High-Risk Positions  : Conduct thorough risk assessments to pinpoint roles within the organization that are exposed to significant corruption risks.

2.   Due Diligence and Background Checks  :

  -   Screening Processes  : Implement stringent background checks and due diligence before hiring or promoting individuals into high-risk positions.

3.   Training and Awareness  :

  -   Specialized Training Programs  : Ensure all personnel in high-risk positions receive specialized training tailored to address specific corruption risks associated with their roles.

4.   Monitoring and Auditing  :

  -   Continuous Oversight  : Regularly monitor and audit the actions and decisions made by those in high-risk positions to ensure compliance with anti-corruption policies.

5.   Clear Reporting and Accountability Mechanisms  :

  -   Establish Protocols for Reporting and Accountability  : Create clear, confidential reporting channels and ensure that accountability mechanisms are in place for any violations.

Why It's Important

Implementing stringent procedures for high-risk positions is critical for:

-   Mitigating Corruption Risks  : Proactively managing high-risk positions reduces the potential for corrupt practices and safeguards the organization.

-   Enhancing Regulatory Compliance  : Adhering to recognized standards like ISO 37001 helps maintain compliance with legal and regulatory frameworks.

-   Building Trust  : Transparent procedures and accountability in high-risk positions enhance trust among stakeholders, investors, and the public.

Examples

-   Example A  :

 -   Context  : A corporation in the energy sector identifies its project procurement roles as high-risk due to their significant budget control and vendor interactions.

 -   Action  : The company enhances its screening processes, provides targeted anti-corruption training, and sets up a robust system for regular audits.

 -   Outcome  : Improved compliance and a reduction in incidents of bribery and corruption.

-   Example B  :

 -   Context  : A financial services firm recognizes the susceptibility of its loan officers to corruption risks.

 -   Action  : The firm establishes a dual-control system, enhances whistleblower protections, and conducts frequent integrity audits.

 -   Outcome  : Strengthened internal controls lead to early detection of potential corrupt practices and disciplinary actions.

For additional insights and guidance on establishing procedures for high-risk positions, refer to the following resources:

- [Practical Guide: The corporate anti-corruption compliance](https://www.agence-francaise-anticorruption.gouv.fr)

- [Business Approaches to Combating Corrupt Practices](https://www.oecd.org/daf/anti-bribery)

- [Anti-Bribery Guidance | Transparency International](https://www.antibriberyguidance.org)

These steps and resources equip organizations with the necessary tools to implement effective procedures for managing roles at higher risk of corruption, ensuring compliance with international anti-corruption standards.