Senior management is the body in charge of taking ultimate responsibility for activities related to the organization’s governance and anti-bribery policies. Thus, it must ensure that the organization’s strategy, anti-bribery policy, and objectives are in line. This requires establishing, implementing, maintaining and continually reviewing these mechanisms to adequately address the risks of bribery.
It is essential that senior management adopts an approach that integrates the company’s processes properly, under the requirements of the Anti-Bribery Management System (ABMS), and has sufficient resources for effective operation to achieve the objectives. Also, it should encourage the use of procedures for reporting suspected bribery, as well as actual bribery, promoting an appropriate anti-bribery culture within the business.
Also, senior management may assign partially or fully the anti-bribery compliance function to persons outside the organization, and, if it decides to do so, senior management must ensure that designated personnel bear responsibility and authority for those parts of the function assigned externally.
The Anti-Bribery Management System (ABMS) directly affects the business management and requires the leadership and commitment of senior management to take all future actions and decisions.