1. Commitment and support from senior management
Initiative and unequivocal commitment from the company's senior management, evidenced by visible support for the program, as well as the allocation of adequate resources.
2. Risk assessment
Conducting a risk analysis and its periodic reassessment, involving planning, interviews, documentation, and establishing necessary remediation measures. The risk assessment should consider each company's individual characteristics, objectives, size, structure, market in which it operates, degree of interaction with the public sector, among other factors.
3. Rules and instruments
Creation or improvement of standards of conduct, code of ethics, integrity policies and procedures, applicable to all employees, regardless of their position or function, extended, when necessary, to third parties, such as suppliers, service providers and agents.
4. Internal controls
Internal controls are mechanisms that, in addition to minimizing operational risks, ensure that company documents and records fully and accurately reflect its business operations, guaranteeing the reliability of information.
provided.
5. Training and communication
Dissemination of the company's values, standards, policies, procedures, and ethical conduct. Training is provided to employees, which may be extended to third parties. Continuous reinforcement is provided through materials and news.
6. Reporting channels
Implementation of a mechanism for anonymous reporting of inappropriate conduct or suspected inappropriate conduct.
7. Internal investigations
Processes that enable investigations to promptly respond to reports of illicit or unethical behavior. Investigation of facts, determination of what occurred, whether there was improper conduct, the circumstances and individuals involved, and whether there was a violation of laws or policies.
8. Due diligence
Prior assessment of contracting business partners or suppliers to verify their integrity, which may include: corporate and financial structure, history of unethical business practices, involvement in lawsuits, among others.
9. Continuous monitoring
A continuous evaluation process to improve the compliance program. Verification that the implemented pillars are functioning as planned, that the expected effects are materializing, and that risks are being controlled. Measure to manage.
Montgomery is able to assist clients in implementing or improving their compliance program.
We remain at your disposal for any clarification.
