Monitoring Anti-corruption. The Board and senior management are required to ensure that the anti-corruption control systems in place are monitored regularly concerning the quality of the system's performance. The scope and frequency of such evaluation must ensure that separate evaluations are carried out, namely, audits of internal investigation activities, in light of the assessment of risks and the effectiveness of the ongoing monitoring procedures.
Anti-corruption Compliance Program. The Board and senior management ensure that HD Faculty™'s anti-corruption compliance program consists of the following:- Zero defect mentality with respect to compliance.
- Compliance requirements that are identified and communicated to the various business
units in respect to HD Faculty™'s worldwide overall risk assessment process.
- Integration of Compliance activities in the day-to-day business operations.
- The person in charge of a given process is assigned to the compliance programs, with the
responsibility of ensuring that they are operating in accordance with HD Faculty™'s risk
management and anti-corruption program.
- Compliance programs are being monitored through an ongoing and periodic monitoring
activity system that requires management and supervisory action through internal and
external compliance audit programs.
