企業コンプライアンス責任者キット

CMS manual: scope, obligations register, compliance risk assessment, policy and roles, controls, concerns and investigations, KPIs, audit, review

Corporate ethics code: leadership message, decision test, speak-up channels, bribery, gifts, conflicts, competition, sanctions, records, waivers, training

Corporate policy: purpose, scope, numbered statements, roles, compliance and exceptions, enforcement, definitions, review, approval

Bribery risk assessment, policy, anti-bribery function, financial and non-financial controls, third-party due diligence, gifts register, conflicts, legal examples

Scope and size test, governance, scales, scheme inventory, inherent and residual scoring, anti-fraud controls, override, analytics, six principles, actions

Regimes, governance, list management, customer and payment screening, ISO 20022 fields, fuzzy thresholds, alerts, freezing, OFAC/OFSI reporting, testing

Conflicts policy, governance RACI, identification triggers, Art. 33 criteria, L x I rating, register, controls, last-resort disclosure, inducements, breaches, MI

Who and what is covered, internal channels, external reporting, confidentiality and anonymity, non-retaliation, 7-day and 3-month timelines, investigation, SOX 301 routing, records, KPIs, country annex