It is undoubtedly essential and recommended for every organization to have an ABAC policy since it is one of the cornerstones of effective compliance. However, it is not just necessary to have a policy in place. It is also imperative that the organizations ensure its effectiveness by customizing it as per its requirements and keeping it up to date with evolving times. 

Firstly, the ABAC policy of a company should be user-friendly. By that, it means that the company should ensure that the policy is drafted in one or more languages if the need be. The language of drafting should be simple and easy to understand.  One shouldn't require a legal background to understand the policy! Further, in today's time of wide spread internet connectivity, it can be made easily accessible to all employees. For the employees that work in plants or on off-site projects with less or no access to the internet, do it the old school way and distribute hard copies of the policies! 

Secondly, companies should opt to link their ABAC Policy to their Code of Ethics. For an effective compliance program, both these documents should be in sync. As rightly pointed out by Klaus Moosmayer, the Chief Ethics, Risk & Compliance Officer of Novartis, the code of ethics is ultimately the “moral constitution” of every organization, and its principles and commitments should cover the purpose and risks of the respective corporation. 

Thirdly, the ABAC policy should preferably lay down steps to be taken by the company in case of misconduct. Adjudicating authorities in recent times have been emphasizing for companies to get to the bottom of a misconduct. The ABAC policy needs to lay down the step-by-step procedure for investigation and the remediation measures to make the related process watertight and reliable.  

Fourthly, companies need to talk about ethics and create a culture where employees feel safe approaching the management in case of any grievance. Provisions guaranteeing anonymity and protection to a whistleblower should be vital for an effective ABAC policy. It helps employees feel safe about flagging a concern without having to worry about retaliation. 

Finally, it is crucial that organizations focus on training and spreading awareness about the ABAC policy of the company- as early as during the recruitment process. It helps build a robust and ethical culture when new recruitees are also aware of the company's strict no-corruption/bribery stance! Training in regular intervals helps the employees familiarize themselves with the policy and allows them to incorporate the anti-bribery and corruption approach into their day-to-day work. 

Author: Rakhi Mohanty

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Reference:

A comprehensive anti-bribery policy is essential, but not enough by Klaus Moosmayer from Fcpablog.com