Certification - CAC 40 Group
The subsidiary of a Group specialized in aerospace and defense has asked ADIT to certify its anticorruption compliance program.
This certification evaluates the maturity level and effectiveness of the entity’s aforementioned program. The ADIT 2018 benchmark used within this framework is comprised of over 200 control points. All of them have been elaborated in order to comply with the legislative requirements, such as the Sapin II law, UKBA, FCPA, etc., and take into account some specificities issued from the jurisprudence and official guidelines. These control points are based on the five categories of the Committee of Sponsoring Organizations of the Treadway Commission (COSO), as well as on the international best practices and standards and reference standards such as ISO 37001.
The certification procedure is divided into four steps. First, interviews with the key people in the compliance, sales, business, legal, etc., departments aim to understand the entity’s environment and to assess the effectiveness of the compliance program. Then, the document review enables to verify the relevance of the implemented measures in view of the requirements and risks specific to the entity. This step is followed by the analysis of the business partners’ files which enables to focus on the risk areas regarding the management of third parties. Finally, payments made to third parties are sampled and checked based on account extracts. The aim is to verify the accounting and justifications.
At the end of this audit, the entity can either be certified, certified under the condition it implements corrective measures or not certified at all. ADIT works with the entity to better its compliance procedure.