A FTSE SMALL CAP Company Secretary writes...
A newly appointed Small Cap Company Secretary is being asked by his new Board about the need to appoint a Bribery and Corruption Officer – and there is some suggestion that the role should fall into the scope of the role of a Company Secretary. The newly appointed Company Secretary is not so sure; What experience do others have of undertaking such a post as part of Co Sec duties? Does anyone have views on whether these roles could/should be combined?
We have a cross-functional working group, which owns our adequate procedures approach – Chaired by GC. CoSec is a member. Legal needs to have a central role, and Finance processes are crucial – which maybe takes it beyond the traditional CoSec role. My impression is that Legal are the usual owners.
We are a small listed company with international operations and we have an Anti-bribery and Corruption compliance programme. We don’t have a “Bribery and Corruption Officer” and don’t see the need for one. A typical job role summary for such a role would be:
“Role summary
The Bribery Act 2010 (BA 2010) requires all businesses with a trading presence in the UK to have adequate procedures to prevent bribery. The ABC Officer is responsible for ensuring systems and controls are of the required standard to enable [insert organisation name], including its managers and employees, to comply with these obligations.”
Each listed company is different, with different compliance issues and management structures so maybe this role is something that could come within the ambit of the Company Secretary’s responsibilities. But it doesn’t sound like it fits there. It’s more a Legal or Compliance function. In our company the Head of Internal Audit and Risk would cover these responsibilities