Assign anti-bribery responsibilities to first line, second line, and third line roles.
Assign each anti-bribery activity to its primary Three Lines role. First line owns/manages risk Second line supports/challenges Third line assures independently Sales documents why a distributor is needed for a public-sector opportunity Compliance designs enhanced due diligence standards for high-risk agents Internal audit tests whether distributor invoices match approved scopes Finance blocks payment to a bank account that does not match the approved vendor Compliance reviews trends in gift approvals involving public officials Internal audit reports control design gaps to the audit committee Procurement verifies vendor onboarding documents before contract signature Risk team challenges whether country risk ratings are current…
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