Tagged: conflicts of interest

ISO 37001: Risk Assessments, Employees, and Due Diligence Requirements (Part IV of V)

In Part IV of my series on ISO 37001, I examine requirements relating to risk assessments, design of policies and procedures, and due diligence requirements. Section 4.5 sets out requirements for conducting risk assessments. ISO 37001 requires companies to conduct regular risk assessments in order to identify the bribery risks the company might reasonably anticipate; analyze, assess and prioritize the identified bribery risks; and evaluate...

The Importance of A Robust Conflicts of Interest Program

It is always interesting to learn how companies handle specific compliance issues. Years ago, I could always tell when a compliance department was lacking in stature and independence in a company. Typically, I observed three important indicators – a compliance department that was stuck in the legal department reporting to the general counsel; mired in detailed gifts, meals and entertainment reviews and approvals; and devoted...