The Bank adopts a risk based approach in managing its bribery and corruption risks. All lines of businesses (LOB) and support functions are required to conduct risk assessments on a periodic basis.
All LOBs and support functions must identify areas of their business that maybe prone to bribery and corruption risks and establish controls to mitigate risks identified and validate on a regular basis that the controls are effective and performing as intended.
All risk assessments must be duly documented and available for review.
Business Unit / Department are assessed against the recommended high risk areas as follows:
a. Customer / Vendor facing high risk areas
Political engagement
Confilct of interest
Sponsorship and donation
Gift and hospitality.
Facilitation payments
b. Managing third party high risk areas
Awarding of contract – agents / vendors
On-going engagement
c. Other high risk areas
Human resources – hiring
Procurement
Finance – invoicing and disbursements
The Bank has the option to appoint an external party to conduct risk assessments.
The result of the risk assessment are to be reported to various internal stakeholders within the Bank.
The Bank’s ABCP programme implementation, including risk assessments conducted by LOBs are subject to Group Compliance’s validation and monitoring.
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