Sample Resume : Effective Fcpa Program

1299 Words6 Pages
Answer 1: Effective FCPA program should include: Company must have standards and procedures in place to prevent and detect criminal conduct Board of directors should see whether employees are staying with compliance program Proper training of employees, company officer and third parties on relevant laws and compliance program Monitoring and Evaluating; Anonymous Reporting Company must periodically assess the risk of criminal conduct and take appropriate steps to design, implement, or modify its compliance program Require prior approval of facilitation payments Prohibit all facilities payments in the absence of safety concern Prohibit third party from giving gifts or payments in violation of FCPA Answer 2: Measures companies can take to protect themselves from the action of rogue employees: Monitor employees: Companies should do background check before hiring employees. Monitoring should extend to reminding workers not to be careless in handling company. Companies should try to foster a culture of fairness or positive environment so that employees doesn’t get disgruntled and pose a problem to company. Make sure employees have access to resources they need. There should be restriction of access to sensitive data Have fake data mixed with sensitive data. So that if breach occurs, company can immediately get informed about breach through system. After criminal conduct has been detected, a company must take reasonable steps to respond appropriately and to prevent further

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