Support the CE Officier in matters regarding the Control Environment Committee and Speak-Up process
- Monitor and keep track the investigation process through Speak-up investigation tracker and support to ensure that all the Speak-up case are investigated in time and in confidential manner with clear findings, conclusion.
- Update and take charge of the CEC Speak Up tracking and CEC follow-up action tracker.
- Take lead in coordinating the investigation result report, and to support the CE Officer to report to CEC/ Region as well as assisting CE Officier in development of corrective action plans when areas of opportunities are identified.
- Receive, document, and follow up the status and actions taken of all Speak-up cases receiving via hotline, or by other various means.
- Co-ordinate with Legal and related functions to build up legal compliance annual Plan-Do-Check-Act plan.Support with monitoring the Speak-up line, ensure the efficiency and reliability of the channel for reports of any noncompliance without fear of retribution.
Support in establishing and implement “adequate procedures” to prevent bribes:
- Work with related functions and external trainers (if applicable) to develop training programs for all employees, agents, contractors to raise awareness and enhance compliance of ABC policy, then document the trainings.
- Draft the inputs/ proposal to adapt/ tailor policies/ processes of Suntory and PepsiCo into the local context and expectation of JV.
- Take lead in the trainings of ABC policy (i.e. new hire and annual refreshment), which can include computer-based or live training.
- Develop appropriate compliance programs and support CE Officer in communication and enhancing the quality of such programs.
- Support the CE Officer in ensuring that the Company follows appropriately FCPA, UKBA and local laws on Anti-Bribery and Corruption;
- Regularly revisit the compliance program and recommend and draft appropriate revisions and modifications to evaluate and improve the program’s effectiveness, taking into account relevant developments in the field and evolving international and industry standard, then work with CE Officer to finalise the programs.
- Support the CE Officer in the introduction and implementation of Anti-Bribery and Corruption Policy and its Guidelines (ABC policy) to all employees, including high levels.
- In accordance with the SOPs and guidelines from CEC and Region:
(iii) advise potential compliance risks and how to avoid/ mitigate it.
(i) regularly review and draft inputs/improvements of such SOPs and guidelines, then work with CE Officer to finalise and implement the SOPs/ guidelines
(ii) review pre-approval request and post-reporting form submission and consider the appropriateness of transaction (e.g. the receipt of Gifts, Meals or Entertainment, Corporate Sponsorship, Charitable Donation) in terms of private sectors and take actions when and as necessary.
- Support the Legal Manager in extending compliance measures to third parties and business partners as much as possible. Co-ordinate with all functions to ensure the key suppliers/ customers/ distributors will sign “CoC acknowledgement” and return duly signed version.
- Ensure all compliance trainings/ compliance activities are documented. Keep record and tracking of documents relating to business partner due diligence, internal approval procedure of gift, meal, business entertainment, sponsored travel and donations.
Lead in promoting the Culture of Integrity, making Compliance and Ethics as a part of daily routines
- Leverage all internal channels of communication to promote Compliance & Ethics creatively and effectively.
- Take lead in organizing Control Environment assessment for all locations every 2 years or as requested by CEC (can be outsourced). Analyse the results and support with the reports of the Control Environment result to CEC/ Region, as well as supporting in the setting up of action plans to enhance the strength and close the gap.
- Organize compliance & ethics training program.
- Take charge of CEC quarterly communication “case study and guidelines for compliance” based on the themes decided by CEC.
Co-ordinate and perform legal compliance review
- Co-ordinate with Legal to ensure the aligned corrective/ preventive actions taken as schedule
- Co-ordinate with Legal and related functions to build up legal compliance annual Plan-Do-Check-Act plan.
- Draft the report to CEC (or Audit Committee if necessary) including strengths, the gap, weakness and opportunities and work with Legal Manager to finalise them
- Base on the compliance requirement check-list provided by Legal and the self-assessment of respective functions, develop the detailed check plan.
