Prevention, Detection and Remediation of Fraud and Corruption
|
|
- Donna Harvey
- 5 years ago
- Views:
Transcription
1 Prevention, Detection and Remediation of Fraud and Corruption Presented by Jolyne Sanjak Managing Director, Implementation Support, MCC April 15, 2009
2 What We Already Do: Fiscal Accountability: Program Procurement Guidelines, Procurement and Fiscal Agents, Fiscal Accountability Plan, Financial Audits, Cost Principles. Technical Due Diligence, Oversight and Ex-post reviews: Staff and contracted sector experts, social and environmental specialists, and independent engineers regularly engage the MCA in review and approval processes and periodically conduct independent ex-post sector and procurement reviews of value-for-money; Monitoring and Evaluation: non-sector monitoring experts work with MCA to develop and use plans for monitoring process milestones and results; evaluating impact. Structural: MCC-OIG, Legal agreements e.g. The Compact sets out host-country government responsibility for Compact funds (e.g. reimbursement to MCC for misuse), Character Risk Due Diligence (CRDD) for MCA Staff, MCC Approval rights over MCA structure, disbursement discretion, suspension and termination abilities. These functions begin in Compact development and carry forward until the end of the Compact implementation period; as country capacity grows, MCC hands-on support is reduced while approval processes continue
3 Policy Development Process: Donor and Agency Research and Coordination Definitions of Fraud and Corruption (World Bank, IDB, Asian Development Bank, Expert Roundtable at MCC, IFI Anti-Corruption Task Force) Allegation Processing Procedures and Sanctions (World Bank, IDB, IFI Anti-Corruption Task Force, USAID (FAR only), OPIC (FCPA), DoJ) Possible Requirement of MCA-Entity Compliance Officer (DANIDA)
4 Policy Development Process: Donor and Agency Research and Coordination (continued) MCA-Entity Fraud and Corruption Action Plan (Expert Roundtable at MCC, World Bank) Civil Society Monitors/Consultation Civil Society Monitors/Consultation (Expert Roundtable at MCC, PIR participation in OSI conference, Princeton Research)
5 Approval of a Policy that: Clearly articulates the importance of preventing F&C and managing the associated risks Makes clear the scope of MCC concerns on F&C Calls for greater consistency in actions (including reporting) Defines the array of administrative actions that MCC management may determine to take
6 Fraud and Corruption: Three areas of focus Checks and balances MCC and MCA systems in place already as well as planned for future development Prevention Detection Techniques for determining when activities suggest fraudulent or corrupt activity. Remediation MCC response and reporting options and procedures
7 Fraud and Corruption: What s New: Prevention MCC model already includes a number of checks and balances which can be effective but are mostly reactive (e.g. approvals process, Procurement and Fiscal Agents, transparency requirements) Biggest change going forward is to require proactive involvement of MCA management MCA Assessments and Action Plans
8 Fraud and Corruption: What s New: Detection To bolster interest in and capacity for detection: Training for MCC and MCA staff Communications strategy Transparency and monitoring supports via civil society engagement
9 Fraud and Corruption: What s New: Remediation Clarification that the following administrative measure may be applied to mitigate risk: Prohibition of contractors from participation in MCC funded programs; Administrative measures: ineligibility, removal from a procurement, adverse performance rating, withholding of MCC disbursements; Recommendation to MCA management or other appropriate government official to take administrative action; and Termination of the Threshold program or compact
10 Upcoming Milestones: Issuing Version 1.0 of the Tools and Techniques Document Approach to risk assessment and action planning for projects in implementation Approach to use of civil society monitors Procedural guidelines finalized and publicized Training planned and underway
11
Overview of Procurement and Integrity at the EIB. Andreja Neral Lamza & Mirela Lascu, European Investment Bank
Overview of Procurement and Integrity at the EIB Andreja Neral Lamza & Mirela Lascu, European Investment Bank European Investment Bank The EIB: the EU bank Shareholders: 28 EU Member States Around 90%
More informationRisk Management at MCC
Risk Management at MCC Christopher Williams, Director, Investment and Risk Management Division (williamscp@mcc.gov) Presentation at Aid and International Development Forum 2011, Washington, DC June 8,
More informationCombatting fraud and corruption in EIB s operations
Combatting fraud and corruption in EIB s operations The European Investment Bank Group (EIB Group) has zero tolerance of fraud and corruption. The Fraud Investigations Division of the Inspectorate General
More informationTHEMATIC COMPILATION OF RELEVANT INFORMATION SUBMITTED BY UNITED STATES OF AMERICA ARTICLE 12 UNCAC PRIVATE SECTOR AND PUBLIC-PRIVATE PARTNERSHIPS
THEMATIC COMPILATION OF RELEVANT INFORMATION SUBMITTED BY UNITED STATES OF AMERICA ARTICLE 12 UNCAC PRIVATE SECTOR AND PUBLIC-PRIVATE PARTNERSHIPS UNITED STATES OF AMERICA (THIRD MEETING) United States
More informationThe Inter-American Investment Corporation s INTEGRITY FRAMEWORK
The Inter-American Investment Corporation s INTEGRITY FRAMEWORK Adopted on July 27, 2016 INTEGRITY FRAMEWORK I. General Principles 1. Purpose. The purpose of this Integrity Framework is to reiterate the
More informationAdditional reporting and disclosures
Additional reporting and disclosures Corporate governance The EBRD is committed to the highest standards of corporate governance. Responsibilities and related controls throughout the Bank are properly
More informationHundred and Thirty-fourth Session. Rome, October WFP Anti-Fraud and Anti-Corruption Policy
October 2010 FC 134/3 E FINANCE COMMITTEE Hundred and Thirty-fourth Session Rome, 21 22 October 2010 WFP Anti-Fraud and Anti-Corruption Policy This document is printed in limited numbers to minimize the
More informationPOLICY ISSUES. Agenda item 5 WFP ANTI-FRAUD AND ANTI-CORRUPTION POLICY. For information*
Executive Board Annual Session Rome, 7 11 June 2010 POLICY ISSUES Agenda item 5 For information* WFP ANTI-FRAUD AND ANTI-CORRUPTION POLICY E Distribution: GENERAL WFP/EB.A/2010/5-B 24 May 2010 ORIGINAL:
More informationRecovery Accountability and Transparency Board Final Report to Congress on Activities Related to Hurricane Sandy Funds May 2015
Recovery Accountability and Transparency Board Final Report to Congress on Activities Related to Hurricane Sandy Funds May 2015 This is the Recovery Accountability and Transparency Board s (Board) seventh
More informationCARIBBEAN DEVELOPMENT BANK STRATEGIC FRAMEWORK FOR INTEGRITY, COMPLIANCE AND ACCOUNTABILITY PILLARS I AND II INTEGRITY AND ETHICS POLICY
CARIBBEAN DEVELOPMENT BANK STRATEGIC FRAMEWORK FOR INTEGRITY, COMPLIANCE AND ACCOUNTABILITY PILLARS I AND II INTEGRITY AND ETHICS POLICY To provide for measures to promote Institutional Integrity and Ethics
More informationTransnational Corruption Investigations
Transnational Corruption Investigations Intelligence, Evidence, and Remote Detection Tools The Economics of Corruption Passau, October 15, 2009 What happens during an investigation Intake Review Prioritization
More informationWSSCC, Global Sanitation Fund (GSF)
Annex I WSSCC, Global Sanitation Fund (GSF) Terms of Reference Country Programme Monitor (CPM) BURKINA FASO 1 Background The Water Supply and Sanitation Collaborative Council (WSSCC) was established in
More informationCARIBBEAN DEVELOPMENT BANK STRATEGIC FRAMEWORK FOR INTEGRITY, COMPLIANCE AND ACCOUNTABILITY PILLARS I, II AND III WHISTLEBLOWER POLICY
CARIBBEAN DEVELOPMENT BANK STRATEGIC FRAMEWORK FOR INTEGRITY, COMPLIANCE AND ACCOUNTABILITY PILLARS I, II AND III WHISTLEBLOWER POLICY To provide for a Whistleblower System and the protection of Whistleblowers
More informationOutreach Seminar: Business Opportunities in World Bank-Funded Projects FY 2014
Outreach Seminar: Business Opportunities in World Bank-Funded Projects FY 2014 Lending, Trends, and Project Development Cycle Data as of Oct 2014 Fiscal Year 2014 = July 1, 2013 to June 30, 2014 339 Operations
More informationReport on the activities of the Independent Integrity Unit
Meeting of the Board 1 4 July 2018 Songdo, Incheon, Republic of Korea Provisional agenda item 23 GCF/B.20/Inf.17 30 June 2018 Report on the activities of the Independent Integrity Unit Summary This report
More informationSuspected fraudulent acts by partner
[CBPF Form 22.a] Suspected fraudulent acts by partner SCOPE This form is to be used to support the reporting and follow up to cases of suspicion of fraud involving CBPF project partners including Partner
More informationIMF Revenue Mobilization and Development Conference Washington, DC, April 17-19, 2011 Highlights of USAID Tax Technical Assistance Program
IMF Revenue Mobilization and Development Conference Washington, DC, April 17-19, 2011 Highlights of USAID Tax Technical Assistance Program David Dod Office of Economic Growth Bureau for Economic Growth,
More informationMETRICS FOR IMPLEMENTING COUNTRY OWNERSHIP
METRICS FOR IMPLEMENTING COUNTRY OWNERSHIP The 2014 policy paper of the Modernizing Foreign Assistance Network (MFAN), The Way Forward, outlines two powerful and mutually reinforcing pillars of aid reform
More informationNew Development Bank Procurement Policy
New Development Bank Procurement Policy Owner: Operations Division Version: 2015 V4 Revision Date: [10] March 2016 Procurement Policy All rights reserved. Any unauthorized use, duplication or disclosure
More informationDIRECTIVE ON OPERATIONS PROCUREMENT A. OVERRIDING OBJECTIVE B. DEFINITIONS
DIRECTIVE ON OPERATIONS PROCUREMENT August 18, 2017 A. OVERRIDING OBJECTIVE 1. Purpose. The purpose of this Directive on Operations Procurement (Directive) is to enable the Bank s staff to implement the
More informationLaw Enforcement Focus on Energy Programs and Compliance
Law Enforcement Focus on Energy Programs and Compliance Presented to: The Society of Corporate Compliance & Ethics Utilities & Energy Compliance & Ethics Conference February 24, 2014 Houston, Texas Presenters
More informationFraud, Waste and Abuse: Compliance Program. Section 4: National Provider Network Handbook
Fraud, Waste and Abuse: Compliance Program Section 4: National Provider Network Handbook December 2015 2 Our Philosophy Magellan takes provider fraud, waste and abuse We engage in considerable efforts
More informationCompliance Program. Investigation Policy. Purpose. Applicability. Policy. Unity House of Troy, Inc.
Investigations Policy Purpose To thoroughly respond to and investigate all potential compliance violations of federal, state, and local laws and regulations as well as policies and procedures as they apply
More informationGovernance and Fiduciary Issues. An Overview
Governance and Fiduciary Issues An Overview The Agenda Governance Issues Governance Risks in CDD Projects Key Principles of Project Design Lessons Learned Fiduciary Issues Procurement Financial Management
More informationThe OECD Guidelines for Multinational Enterprises
ECD Watch The OECD Guidelines for Multinational Enterprises a tool for responsible business conduct OECD Guidelines about the for Multinational enterprises The OECD Guidelines for Multinational Enterprises
More informationUnique Markets, Responsible Investing
Unique Markets, Responsible Investing IFC s Integrity Due Diligence Process BENEFICIAL OWNERSHIP CLIENT SCREENING SANCTIONS & DEBARMENT AML/CFT INTEGRITY RISK International Finance Corporation 2017. All
More informationAgenda. Strategic Considerations in Resolving Voluntary Government Disclosures
Strategic Considerations in Resolving Voluntary Government Disclosures Health Care Compliance Association Annual Compliance Institute Patrick Garcia Hall, Render, Killian, Heath, & Lyman, P.C. Kenneth
More information2/24/2017. Agenda. Determine Potential Liability. Strategic Considerations in Resolving Voluntary Government Disclosures. Relevant legal authorities:
Strategic Considerations in Resolving Voluntary Government Disclosures Health Care Compliance Association Annual Compliance Institute Patrick Garcia Hall, Render, Killian, Heath, & Lyman, P.C. Kenneth
More informationSIGNIFICANT CHANGES IN ANTI-BRIBERY LAWS IN MEXICO AND COLOMBIA SIGNAL A NEW COMMITMENT TO ANTI-CORRUPTION EFFORTS
SIGNIFICANT CHANGES IN ANTI-BRIBERY LAWS IN MEXICO AND COLOMBIA SIGNAL A NEW COMMITMENT TO ANTI-CORRUPTION EFFORTS September 2017 www.morganlewis.com This White Paper is provided for your convenience and
More informationProcurement. OP January 2011 Page 1 of 10. Revised July 1, 2014
Page 1 of 10 "OP/BP11:00 "Procurement, were revised on July 2014 to take into account the recommendations in " World Bank Group A New Approach to Country Engagement" (R2014-0089), which were approved by
More informationREPORT OF THE OFFICE OF THE INSPECTOR GENERAL
OFFICE OF THE INSPECTOR GENERAL CHICAGO HOUSING AUTHORITY REPORT OF THE OFFICE OF THE INSPECTOR GENERAL 2016 FOURTH QUARTER REPORT OCTOBER 1, 2016 THROUGH DECEMBER 31, 2016 ELISSA RHEE-LEE INSPECTOR GENERAL
More informationFraud Investigations NHS Clinical Commissioning Groups
Fraud Investigations NHS Clinical Commissioning Groups A comparative review of criminal investigations The overall purpose of the insight is to enable individual organisations to consider how they compare
More informationPROCUREMENT POLICIES AND PROCEDURES
PROCUREMENT POLICIES AND PROCEDURES Table of Contents INTRODUCTION... 2 I. GENERAL CONSIDERATIONS... 2 Borrower/Grantee Responsibility... 2 Planning... 2 Applicability... 3 Eligibility... 3 Advance Contracting
More informationPROJECT AGREEMENT. (Hebei Energy Efficiency Improvement and Emission Reduction Project) between ASIAN DEVELOPMENT BANK. and
LOAN NUMBER 2835-PRC PROJECT AGREEMENT (Hebei Energy Efficiency Improvement and Emission Reduction Project) between ASIAN DEVELOPMENT BANK and HEBEI PROVINCIAL GOVERNMENT DATED 6 MARCH 2012 PRC 44012 PROJECT
More informationAnti-money laundering Annual report 2017/18
Anti-money laundering Annual report 2017/18 Anti-money laundering Contents 1 Introduction 4 2 Policy developments 5 3 OPBAS 7 4 How our AML supervision is evolving 8 5 Findings and outcomes 9 6 Financial
More informationProgram-for-Results Financing
Program-for-Results Financing D E C E M B E R 2 0 1 1 the world bank What is Program-for-Results? In today s world, development is about results. Everyone government officials, parliamentarians, civil
More informationImplementation Support Workshop February 06-10, 2012 Ankara The World Bank
REVISION OF PROCUREMENT AND CONSULTANT GUIDELINES January 2011 Implementation Support Workshop February 06-10, 2012 Ankara The World Bank Background The Guidelines have evolved over the years to reflect
More informationGAMAS means Mongolia Customs Automated Data Processing
2 System; (c) GAMAS means Mongolia Customs Automated Data Processing (d) Grant Account means the account opened by ADB on its books in the name of Mongolia for the purposes of the Project and to which
More informationEstablishing an Anti-Corruption Compliance Program in Canada
PUBLICATION Establishing an Anti-Corruption Compliance Program in Canada Date: August 14, 2012 Lawyers You Should Know: Henry Chang Original Newsletter(s) this article was published in: International Business
More informationApril 2015 FC 158/12 E. Hundred and Fifty-eighth Session. Rome, May Anti-Fraud and Anti-Corruption Policy
April 2015 FC 158/12 E FINANCE COMMITTEE Hundred and Fifty-eighth Session Rome, 11-13 May 2015 Anti-Fraud and Anti-Corruption Policy Queries on the substantive content of this document may be addressed
More informationNOW, THEREFORE, the UNDP and the Recipient Organizations (hereinafter referred to collectively as the Participants ) hereby agree as follows:
Memorandum of Understanding between the Recipient Organizations and the United Nations Development Programme regarding the Operational Aspects of UN Zika Response Multi-Partner Trust Fund WHEREAS, the
More informationOverseas Private Investment Corporation
Overseas Private Investment Corporation An OPIC Overview US-ASEAN Business Council Roundtable Jakarta, Indonesia June 15, 2015 Our Organization As the U.S. Government s premier development finance institution,
More informationProject Reporting: GCF Legal Agreements and GCF Monitoring & Evaluation
Project Reporting: GCF Legal Agreements and GCF Monitoring & Evaluation ARMENIA De-risking and Scaling-up Investment in Energy Efficient Building Retrofits UNDP-GCF Project INCEPTION WORKSHOP Cynthia Page,
More informationI. Background and Scope... 3 II. Executive Summary... 4 III. Findings... 6
Table of Contents I. Background and Scope... 3 II. Executive Summary... 4 III. Findings... 6 01 Fraudulent procurement of t-shirts, office supplies and silver medals... 6 02 Finding 2 Non-compliant hotel
More informationWHITE PAPER. New DOJ Investigative Measures Target Individuals for Corporate Misconduct
WHITE PAPER New DOJ Investigative Measures Target Individuals for Corporate Misconduct WHITE PAPER New DOJ Investigative Measures Target Employees and Executives for Corporate Misconduct: The Yates Memo
More informationMILLENNIUM CHALLENGE COMPACT BETWEEN THE UNITED STATES OF AMERICA ACTING THROUGH THE MILLENNIUM CHALLENGE CORPORATION AND THE REPUBLIC OF NAMIBIA
MILLENNIUM CHALLENGE COMPACT BETWEEN THE UNITED STATES OF AMERICA ACTING THROUGH THE MILLENNIUM CHALLENGE CORPORATION AND THE REPUBLIC OF NAMIBIA ANNEX VI MCA-NAMIBIA PROCUREMENT RULES Index of Amendments
More informationSubgrantee Monitoring and Risk Assessment Principles. Brian Sass, OVC
Subgrantee Monitoring and Risk Assessment Principles Brian Sass, OVC Objectives I. Become familiar with the rules and regulations requiring the monitoring of VOCA Victim Assistance subawards II. III. IV.
More informationJames Sale Project Officer, Pharmaceuticals & Healthcare Programme (PHP) Transparency International UK
James Sale Project Officer, Pharmaceuticals & Healthcare Programme (PHP) Transparency International UK UK HEALTH SYSTEM The National Health Service (NHS) is the world s largest publicly funded health service.
More informationAn Introduction to the American Recovery and Reinvestment Act of 2009: Implications for Construction Contractors May 26, 2009
An Introduction to the American Recovery and Reinvestment Act of 2009: Implications for Construction Contractors May 26, 2009 2009 Crowell & Moring LLP All Rights Reserved Stimulus Act Oversight and Fraud,
More informationCulture and Compliance Programs: Practical Advice Compliance and a Culture of Integrity Conference Hofstra University October 29, 2014
Culture and Compliance Programs: Practical Advice Compliance and a Culture of Integrity Conference Hofstra University October 29, 2014 Matthew Heiman Vice President, Chief Compliance & Audit Officer Thomas
More informationWorld Bank HIV/AIDS Program
blic Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized World Bank HIV/AIDS Program A Guidance Note on Disbursement Procedures This document was
More informationINSURANCE. Forensic services. Helping to protect your business from fraud, misconduct and non-compliance ADVISORY. kpmg.com/in
INSURANCE Forensic services Helping to protect your business from fraud, misconduct and non-compliance ADVISORY kpmg.com/in The insurance industry has been growing at a fast pace in India. To differentiate
More informationPROCEDURE ON THE ENGAGEMENT OF AGENTS AND GOVERNMENT INTERMEDIARIES. Group Legal, Ethics and Compliance
PROCEDURE ON THE ENGAGEMENT OF AGENTS AND GOVERNMENT INTERMEDIARIES PROCEDURE CUSTODIAN Group Legal, Ethics and Compliance DATE vember 2014 1. Introduction The nature of the industry in which AngloGold
More informationIt s Here: The Final 60 Day Overpayment Rule
It s Here: The Final 60 Day Overpayment Rule (What it means for you and your clients) Hillary M. Stemple, Esq. Associate Arent Fox LLP Washington, DC 20006 hillary.stemple@arentfox.com December 5, 2017
More informationMENTAL HEALTH MENTAL RETARDATION OF TARRANT COUNTY. Board Policy. Number A.3 July 31, 2001 COMPLIANCE PLAN
MENTAL HEALTH MENTAL RETARDATION OF TARRANT COUNTY Board Policy Board Policy Adopted: Number A.3 July 31, 2001 OVERVIEW COMPLIANCE PLAN As adopted by the Board of Trustees on July 31, 2001 The Board of
More informationProgram-for-Results Financing 1
Operational Manual BP 9.00 - Program-for-Results Financing These procedures were prepared for use by World Bank staff and are not necessarily a complete treatment of the subject. BP 9.00 February, 2012
More informationFCPA: Enforcement, Investigations and Compliance
FCPA: Enforcement, Investigations and Compliance Association of Corporate Counsel Austin Chapter October 14, 2014 Michael Marinelli, Greenberg Traurig, Austin Sandra Gonzalez, Greenberg Traurig, Austin
More informationCOMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS
EUROPEAN COMMISSION Brussels, 13.10.2011 COM(2011) 638 final COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE
More informationSection 3.07 is deleted and the following is substituted therefor:
2 outstanding Loan and the Fixed Spread that will be applied to new Loans (expressed as a percentage per annum), by (ii) the principal amount of the outstanding Loan on which the Borrower shall pay interest
More informationPROCUREMENT IN WORLD BANK INVESTMENT PROJECT FINANCE BORROWER S PROCUREMENT PROCEDURES (DRAFT)
PROCUREMENT IN WORLD BANK INVESTMENT PROJECT FINANCE BORROWER S PROCUREMENT PROCEDURES (DRAFT) JULY 8, 2014 Draft Borrower s Procurement Procedures ACRONYMS BAFO BOO BOOT BOT CD CDD CPs CQS DC EOI FA IBRD
More informationSession 4 Mainstreaming Anti-Corruption into Climate Finance
Session 4 Mainstreaming Anti-Corruption into Climate Finance Workshop on Corruption Risks and Anti- Corruption Strategies in Climate Finance Manila, Philippines 25 to 27 May 2015 Session objectives and
More informationPreamble. The purpose of this Policy is to protect NIB s reputation and promote a transparent business practice.
Integrity Due Diligence Policy Approved by the Board of Directors on 8 March 2018 with entry into force on 1 May 2018 Preamble NIB follows international standards and good practices regarding know-your-customer
More informationACCREDITATION STANDARDS RELATED TO ANTI- MONEY-LAUNDERING / COUNTERING THE FINANCING OF TERRORISM
Adaptation Fund Board Ethics and Finance Committee Twenty-third meeting Bonn, Germany, 9-10 October 2018 9 September 2018 Agenda item 6 ACCREDITATION STANDARDS RELATED TO ANTI- MONEY-LAUNDERING / COUNTERING
More informationAnti-Corruption Guidance
Anti-Corruption Guidance October 2014 Japan International Cooperation Agency (JICA) Table of Contents I II III IV V VI VII Introduction Purpose and Common Principles Definitions Target Readers and Regulatory
More informationCOMPLIANCE ACTIVITY REPORT
2 1 006 6 COMPLIANCE ACTIVITY REPORT CONTENTS STATEMENT BY THE CHAIRMAN OF THE BOARD OF THE INTERNATIONAL INVESTMENT BANK STATEMENT BY THE CHAIRMAN OF THE BOARD 1 INTRODUCTION 2 CORE ACTIVITY 3 Since the
More informationTerms of Reference for the Fund Operator The EEA and Norway Grants Global Fund for Regional Cooperation EEA and Norwegian Financial Mechanisms
Terms of Reference for the Fund Operator The EEA and Norway Grants Global Fund for Regional Cooperation EEA and Norwegian Financial Mechanisms 2014-2021 Table of Contents 1. Introduction... 3 1.1 Objectives
More informationAmgen GLOBAL CORPORATE COMPLIANCE POLICY
1. Scope Applicable to all Amgen Inc. and subsidiary or affiliated company staff members, consultants, contract workers, secondees and temporary staff worldwide ( Covered Persons ). Consultants, contract
More informationOffice of Inspector General. Regional Enforcement Efforts and Priorities in Florida. South Atlantic Regional Conference January 28, 2011
Office of Inspector General Regional Enforcement Efforts and Priorities in Florida Health Care Compliance Association South Atlantic Regional Conference January 28, 2011 Felicia Heimer, Esq. Office of
More informationRepublic of Niger. Redacted Report. Niger Basin Water Resources Development and Sustainable Ecosystems Management Project APL 1
Republic of Niger Niger Basin Water Resources Development and Sustainable Ecosystems Management Project APL 1 Niger Second Emergency Food Security Support Project Redacted Report February 2016 Statement
More informationAnnex 2: SSHF Memorandum of Understanding [Template] STANDARD MEMORANDUM OF UNDERSTANDING (MOU) FOR SOUTH SUDAN HUMANITARIAN FUND
A Annex 2: SSHF Memorandum of Understanding [Template] STANDARD MEMORANDUM OF UNDERSTANDING (MOU) FOR SOUTH SUDAN HUMANITARIAN FUND Memorandum of Understanding between Participating UN Organizations 1,
More informationSills Egsgard LLP Bulletin: Corporate Social Responsibility and Corruption: Fulfilling CSR goals without violating anti-corruption laws
Sills Egsgard LLP Bulletin: Corporate Social Responsibility and Corruption: Fulfilling CSR goals without violating anti-corruption laws Corporate social responsibility ( CSR ) is increasingly important
More informationSustainable Island Resource Framework Fund OAS / Department of Environment Antigua and Barbuda
Sustainable Island Resource Framework Fund OAS / Department of Environment Antigua and Barbuda Marko Markov, St. John`s, 23 February 2016 1 WHAT IS SIRFF Special Fund established under the EPMA Independent
More informationCOMPLIANCE AND MANDATORY DISCLOSURE OBLIGATIONS FOR GOVERNMENT CONTRACTORS
COMPLIANCE AND MANDATORY DISCLOSURE OBLIGATIONS FOR GOVERNMENT CONTRACTORS Bob Wagman Jeff Vaden May 17, 2017 WHAT WE ARE GOING TO COVER Federal Sentencing Guidelines for Organizations Background Recent
More informationThe Global Fund. Financial Management Handbook for Grant Implementers. December 2017 Geneva, Switzerland
The Global Fund Financial Management Handbook for Grant Implementers Geneva, Switzerland This page has been intentionally left blank Table of Contents 1 Executive Summary... 4 1.1 Introduction... 4 1.2
More informationIntroduction Chapter 1, Page 1 of 9 1. INTRODUCTION
Introduction Chapter 1, Page 1 of 9 1. INTRODUCTION 1.1 OVERVIEW Preamble 1.1.1 The African Development Bank is the premier financial development institution in Africa dedicated to combating poverty and
More informationCorporate Compliance Program Overview
Corporate Compliance Program Overview Posted as Required by California Health & Safety Code s 119400-119402 Mobius Therapeutics, LLC (Mobius) is committed to conducting business in compliance with federal,
More informationAGENDA OPTIMIZING YOUR CODE OF CONDUCT
SHELL INTERNATIONAL EXPLORATION & PRODUCTION OPTIMIZING YOUR CODE OF CONDUCCT TINA I. BRYAN ETHICS & COMPLIANCE OFFICER 10-FEB-2009 AGENDA o o o o CODE BENEFITS EMBEDDING THE CODE ENFORCING THE POLICIES
More informationUsing Data Analytics to Detect Fraud
Using Data Analytics to Detect Fraud Data Analysis Tests for Detecting Corruption 2018 Association of Certified Fraud Examiners, Inc. Corruption Schemes Involve employees use of their influence in a business
More informationThe Global Fund Policy to Combat Fraud and Corruption
The Global Fund Policy to Combat Fraud and Corruption 15 November 2017 1 1. BACKGROUND & PURPOSE Fraud and Corruption Impede the Global Fund s Mission. The Global Fund recognizes that fraud and corruption,
More informationSuffolk Care Collaborative. Compliance Program. And. Compliance Guidelines
Suffolk Care Collaborative Compliance Program And Compliance Guidelines Revised Version Approved by the Board of Directors on October 8, 2015 Implementation Date: July, 2015 Revision Date: July, 2015 (updated
More informationMulti-Donor Health Results Innovation Trust Fund Grant Agreement
Public Disclosure Authorized OFFICIAL DOCUMENTS MDTF-HRI GRANT NUMBER TF019258 Public Disclosure Authorized Public Disclosure Authorized Multi-Donor Health Results Innovation Trust Fund Grant Agreement
More informationThe European Investment Bank. Lessons learnt and challenges on transparency and accountability. Xavier Sol 16/10/2017
The European Investment Bank Lessons learnt and challenges on transparency and accountability Xavier Sol Presentation of Counter Balance Coalition of 9 European NGOs created in 2007, with a Brussels-based
More informationREQUIRED DOCUMENT FROM HIRING UNIT
Terms of reference GENERAL INFORMATION Title: Finance Management Technical Assistance Consultant for the Global Fund Principal Recipient Aisyiyah (National Consultant) Project Name: Management and Technical
More informationEXTERNAL AUDIT AND OVERSIGHT TOPIC GUIDE COMPILED BY THE ANTI-CORRUPTION HELPDESK
EXTERNAL AUDIT AND OVERSIGHT TOPIC GUIDE COMPILED BY THE ANTI-CORRUPTION HELPDESK Transparency International is a global movement with one vision: a world in which government, business, civil society and
More informationBRIBERY IN INTERNATIONAL BUSINESS TRANSACTIONS
BRIBERY IN INTERNATIONAL BUSINESS TRANSACTIONS GLOBAL Headquarters the gregor building 716 West Ave Austin, TX 78701-2727 USA TABLE OF CONTENTS I. INTRODUCTION 1BCourse Overview... 2 94BMajor International
More informationFRAUD POLICY. Fraud Policy-001
Effective Date: March 28, 2018 Owned by: Fraud Committee Review Cycle: Biennial Last Approved: March 28, 2018 Approved By: Executive Management Committee Revision History Revisions to Policy documents
More informationCOMPLIANCE OF THE UNITED STATES OF AMERICA THE INTER-AMERICAN CONVENTION AGAINST CORRUPTION REPORT OF CIVIL SOCIETY COMMITTEE OF EXPERTS WITH TO THE
COMPLIANCE OF THE UNITED STATES OF AMERICA WITH THE INTER-AMERICAN CONVENTION AGAINST CORRUPTION REPORT OF CIVIL SOCIETY TO THE COMMITTEE OF EXPERTS AUGUST 13, 2010 COMMITTEE OF EXPERTS OF THE FOLLOW-UP
More information2017 Year-End Review: Anti-Corruption Trends and Other Corporate Enforcement Issues
2017 Year-End Review: Anti-Corruption Trends and Other Corporate Enforcement Issues January 25, 2018 Davis Polk & Wardwell LLP CLE CREDIT AVAILABLE Agenda 2017 Facts and Figures DOJ Developments FCPA Corporate
More informationRecurrent Integrity Issues in Procurement. Gianpiero Antonazzo Senior Investigator INTEGRITY VICE PRESIDENCY
Recurrent Integrity Issues in Procurement Gianpiero Antonazzo Senior Investigator INTEGRITY VICE PRESIDENCY The Bank s stance against corruption Jim Wolfensohn was the first to mainstream this agenda in
More informationPART I - DEFINITIONS & PRINCIPLES. Date 11 May 2015
PART I - DEFINITIONS & PRINCIPLES Date 11 May 2015 secretariat@robertcarrfund.org Fund Management Agent: Aids Fonds Keizersgracht 392 1016 GB Amsterdam +31 (0)206262669 secretariat@robertcarrfund.org www.robertcarrfund.org
More informationCONTRACTOR S GUIDE TO SUBMITTING A DISCLOSURE
The Department of Defense CONTRACTOR S GUIDE TO SUBMITTING A DISCLOSURE OFFICE OF THE INSPECTOR GENERAL JUNE 2017 TABLE OF CONTENTS SECTION PAGE NUMBER Purpose 3 Definitions 4 Making a Contractor Disclosure
More informationFinancial Policies and Procedures Preventing Bribery, Corruption and Money Laundering (August 2018)
Institute of Development Studies Financial Policies and Procedures Preventing Bribery, Corruption and Money Laundering (August 2018) Contents Page 1. Introduction 1 2. Principles 4 3. Bribery prevention
More information, Honorable Tendai Biti Minister of Finance Ministry of Finance
Public Disclosure Authorized -.... The World Bank 1818 H Street N.W. (202) 473-1000 INTERNATIONAL BANK FOR RECONSTRUCTION AND DEVELOPMENT Washington, D.C. 20433 Cable Address: INTBAFRAD INTERNATIONAL DEVELOPMENT
More informationCSE s ANTI-FRAUD POLICY (AFP-CSE) MARCH 2015
CSE s ANTI-FRAUD POLICY (AFP-CSE) MARCH 2015 0 Policy version control and document history: The CSE anti-fraud policy Title CSE anti-fraud policy Version 1.0 published in March 2015 Source Language Published
More informationSTANDARD MEMORANDUM OF UNDERSTANDING (MOU) FOR UN CIVIL SOCIETY TRUST FUND
STANDARD MEMORANDUM OF UNDERSTANDING (MOU) FOR UN CIVIL SOCIETY TRUST FUND 1 Memorandum of Understanding between Participating UN Organizations 1 and the United Nations Development Programme regarding
More informationDOCUMENTS CO-FINANCING FRAMEWORK AGREEMENT. between ASIAN INFRASTRUCTURE INVESTMENT BANK. and INTERNATIONAL BANK FOR RECONSTRUCTION AND DEVELOPMENT
IOFFICIA DOCUMENTS CO-FINANCING FRAMEWORK AGREEMENT between ASIAN INFRASTRUCTURE INVESTMENT BANK and INTERNATIONAL BANK FOR RECONSTRUCTION AND DEVELOPMENT and INTERNATIONAL DEVELOPMENT ASSOCIATION April
More informationJoint Partnership Arrangement
Joint Partnership Arrangement Concerning Common Arrangements for Joint Support to the Health Strategic Plan 2008-2015 between the Royal Government of Cambodia and the 2nd Health Sector Support Program
More informationPCAOB Update. Maryland Association of CPAs 2014 Accounting Education Conference
PCAOB Update Maryland Association of CPAs 2014 Accounting Education Conference Jeanette M. Franzel, Board Member Public Company Accounting Oversight Board January 10, 2014 Columbia, MD The views I express
More informationPCAOB Update. Maryland Association of CPAs 2014 Accounting Education Conference
PCAOB Update Maryland Association of CPAs 2014 Accounting Education Conference Jeanette M. Franzel, Board Member Public Company Accounting Oversight Board January 10, 2014 Columbia, MD 2 The views I express
More informationSelf-Disclosure: Why, When, Where and How
American Bar Association Washington Health Law Summit Self-Disclosure: Why, When, Where and How December 8, 2015 Margaret Hutchinson U.S. Attorney s Office for the Eastern District of Pennsylvania Kaitlyn
More information