Compliance embedded as company culture and policy . Recognizing antitrust as a risk that your company needs to address Obtaining management commitment . Code of Conduct and/or Statement of Business Principles . Integrate into other programmes and controls . Ongoing and sustained senior management commitment . Compliance organization and resources Compliance leadership and organization . Regular reporting to senior management Adequate resourcing Risk identification and assessment . Understanding the company’s overall approach to risk management . Applying the same methodology to antitrust Introducing or improving control points Effectiveness of control points . Antitrust compliance know-how . Antitrust know-how: manuals, handbooks, guides . Antitrust training . Find ways to stimulate positive employee engagement . Information about antitrust investigations Antitrust concerns-handling systems . Recognition of the value of antitrust concerns-handling systems Different kinds of internal reporting systems Whistleblowing . Communicate, educate and a culture of speaking up . e. Non-retaliation and confidentiality f. The company’s prompt and fair response to a concern . g. Measuring effectiveness 6. Handling of internal investigations a. Types of internal investigations b. Things to consider/practical tools and tips . 7. Disciplinary action . a. General requirements for disciplinary proceedings b. Potential aggravating and mitigating factors c. Specific considerations in antitrust cases 8. Antitrust due diligence a. Due diligence in hiring new employees b. Due diligence in assessing substantive compliance c. Antitrust assessments (audits)selective deep dives . d. Due diligence in relation to trade associations . e. Due diligence in M&A situations . f. Practical tips for due diligence . 9. Antitrust compliance certification . a. Individual certification of compliance b. Certification by a third party NGO c. Governmental certification of compliance programmes . 10. Compliance incentives a. Why have compliance incentives? . b. Types of incentives . 11. Monitoring and continuous improvement a. Monitoring and assessing processes and controls b. Measuring effectiveness of processes and controls c. Auditing and benchmarking d. Monitoring and assessing substantive compliance e. Compliance programme improvement plan . .
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