Business integrity support

Developing and implementing organisation-wide procedures on business integrity practice

Evaluating a client's business integrity values, procedures and practices:

• internal policies and practices with reference to: improper payments/bribes/ kickbacks
• conflict of interest
• competition
• confidentiality of information
• harassment
• employee/labour relations, and other business integrity issues

Assessing key issues and dilemmas at company wide and operational division levels.

Advise on how to manage business integrity issues in politically and commercially difficult operating environments, (e.g. handling bribery, corruption, and the management of agents).

Training and education of employees and contractors with reference to these business integrity policies and practices (manner, breadth, frequency, new hires, refreshers).

• Designing and implementing training workshops to conduct scenario planning exercises.
• Training of employees and contractors regarding specific issues and scenarios - at head office and in-country

System to monitor compliance (documentation; written compliance acknowledgements; frequency, delineation of responsibilities)

Record-keeping processes

Impact of violations of policies

Management of political donations - corporate and in business units

Management of gifts and entertainment practices

Process to identify applicable laws and regulations, and updates, in jurisdictions of operation

Role in advocacy re business integrity

Awareness of position of third parties with reference to business integrity issues (ie, Transparency International, other NGOs and companies)

Support or engagement with government representatives

Cultural sensitivity training/education

Internal audits to ensure compliance

External audits to ensure compliance by partners, agents, suppliers and contractors

Retention of Agents, Contractors and Suppliers:

• Nature and extent of due diligence
• Decision making on engagement
• Contractual commitments/undertakings re business integrity
• Ongoing monitoring, audits, due diligence, certification
• Education of agent, contractor and supplier on business integrity practices
• Requirement for tendering processes

Partners:

• Nature and extent of due diligence
• Decision making on partnership
• Contractual commitments/undertakings re business integrity
• Ongoing monitoring, audits, due diligence, certification
• Education of partners re business integrity practices

Incorporation of business integrity principles in community development and stakeholder engagement activities (i.e. objective selection processes for selection of scholarship candidates, identification of community development priorities)

Overall management system to account for business integrity issues in international operations (i.e. process for identification and management of business integrity issues, linkage to corporate governance management systems)

Applicability of practices to all international operations and activities of the company (i.e. exploration and production, marketing, other sectors)

Creation of bank accounts and management - establishment of controls to constrain business integrity risks in the jurisdiction of operation

Assessment of business integrity context in each operating jurisdiction based on Menas Associates' on-the-ground in-country expertise

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