Question

To prevent corruption, why , top managers should not be given more than one approval authority?

Answer 1

Answers 1

To prevent corruption, why, top managers should not be given more than one approval authority because the compliance manager role, or compliance function, should be undertaken by personnel who have the appropriate competence, status, authority and independence.

1. Competence means that the relevant person(s) assigned the compliance responsibility must have the personal ability to deal with the requirements of the role, and the willingness and enthusiasm to learn about the role and perform it appropriately. As this role is relatively new, and there is only a small pool of people with prior experience of it, the person does not need to have prior experience of such a role.

2. Status means that the relevant person(s) assigned the compliance responsibility must be sufficiently senior in the organisation that other personnel will listen to and respect the person’s opinions.

3. Authority means that the relevant person(s) assigned the compliance responsibility must be granted sufficient authority by the board so as to be able to undertake the compliance responsibilities effectively.

4. Independence means that the relevant person(s) assigned the compliance responsibility must as far as possible not be personally involved in the activities of the organisation which are exposed to corruption risk (see comments above on conflict).

The compliance manager should have direct access to the board in order to communicate relevant information. The compliance manager should not have to report to another manager in the chain who then reports to the board, as these increases the risk that the message given by the compliance function is not fully or clearly received by the board.