Professional Documents
Culture Documents
I. 3. ISO 19600
• High level structure: (i) Context of the organization (ii) Leadership (iii) Planning (iv) Support (v)
Operation (vi) Performance evaluation (vii) Improvement
ISO 37001
Leadership
to. Leadership
•Chapter 5
•Art. 5.1.1 Governing Body
•Art. 5.1.2 Criminal Compliance Body
•Art. 5.1.3 Senior management
• 5.2 Compliance policy
• 5.3 Roles, responsibilities and authorities in the organization
to. Leadership
5.1.1: GOVERNMENT ORGAN: 20 REQUIREMENTS - LEADERSHIP and COMMITMENT (executive decisions
that ensure the approval, application and effectiveness of the SGCP) - MUST:
• VALUES OF THE ORGANIZATION: Promote a culture of Criminal Compliance and act according to the
Legal Order
• PENAL COMPLIANCE MANAGEMENT SYSTEM: ADOPT, IMPLEMENT, MAINTAIN, IMPROVE
• GIVE OF FINANCIAL, material and human RESOURCES
• APPROVE COMPLIANCE POLICY
• ENSURE SGCP EFFICACY: periodically review and modify as necessary
• PENAL COMPLIANCE ORGAN: Establish and endow it with autonomous powers of initiative and control
- WILL OF THE ORGANIZATION: Ensure procedures for:
• Specify the formation of the will
•Take decisions
• Execute decisions to. Leadership
History
Saved
Community
Compliance policy
• Compensation systems for compliance achievements
• Evaluations to employees before hiring
•Continuous training
• Communication continues, open and adequate
• Visible recognition of the achievements of compliance management
• Ethical leadership. "Tone at the top"
• As the hierarchical responsibility of a person in an organization increases, it increases their visibility and
ability to influence the behavior of others.
b. Compliance Culture
• The way of acting (behavior) of the members of Senior Management moves the way of acting of the
rest of the individuals that make up the organization: visible, consistent and sustained commitment over
time with a standard of common behavior
b. Compliance Culture
• The business culture must be an element that positively influences the behavior and attitude of all
those who make up the organization: culture of compliance
b. Compliance Culture
b. Compliance Culture
Change perception detection and punishment
Reduce / eliminate behavior bias
Improve the role of moral considerations
Improve culture (eliminate undue environmental influences / group pressure)
• Application of fast and proportionate disciplinary measures
• Consistency in treatment regardless of position
• Clear criminal compliance policy
• Compensation systems that assess achievement of criminal compliance objectives
• An appropriate initiation or orientation program that emphasizes criminal compliance and the values
of the organization
• Tone in the direction (respect and application from above) • Recognition achievements in compliance •
Continuous, open and adequate communication
The SGCP: Context and Planning
cc: jaumescar - https://www.flickr.com/photos/28842017@N00
c. The SGCP - Context
• The SGCP must be appropriate to the circumstances of the organization in which it operates.
• Chapter 4 deals with aspects related to it (design the management system and maintain it and
continuous improvement).
c. The SGCP - Context
• Understand the organization and its context
• Understand the needs and expectations of the groups of interest
• Determine the scope of the SGCP
c. The SGCP - Context
•Art. 4.1: adequate knowledge of the internal and external circumstances of the organization, as they
condition the design, maintenance and improvement of its management system.
• A criminal compliance management system is only adequate when it is proportional to the
circumstances of the organization and is projected on risks that truly threaten it.
c. The SGCP - Context
• Size and structure of the organization
• Locations and sectors in which it operates or plans to operate
• Nature, scale and complexity of activities
16-abr-19
Saved
Community