Tone from the Top

The most important factor in determining the organization’s resistance where no system of controls can provide absolute assurance against unethical or wrong doing. Organization board or senior management should, however, require the organization to develop comprehensive program.

Risk Assessment   

Organization should establishing the remaining components  of  the  unethical or wrong doing program. It is critically important to review present and potential risks, and to develop mitigating controls.

Policy and Procedures

Should be clearly defined in well documented policies. Detailed underlying procedures should explain how employees, business partners, and third parties should behave, and clearly specify what behavior is unacceptable and noncompliant.

Training and Communication  

Effective programs require careful and continuous communication and training program. Specific training regarding Corporate Integrity and , how it harms the organization, and how to report it should be provided to all members of the organization. In addition, customized training should be provided by function to address seriousness of the risks.

Monitoring and Auditing 

Continuous monitoring activities and individual audits should be performed to ensure the effectiveness of Corporate  Integrity programs.