Today is International Anti-Corruption Day. This
occasion is a good opportunity to think about whether your
organization has sufficient systems, policies and controls in place
to ensure ethical and responsible business practices both at home
For companies active in international business and for
organizations with international operations of any kind, the demand
side of corruption – that is, interactions with government
officials who seek bribes – presents the most acute problem.
An organization's first and best response to corruption is to
establish internal compliance programs and mechanisms to ensure
that employees, partners, and third-party contractors and agents
are aware of and equipped to appropriately respond to bribe
Elements that are frequently present in effective compliance
Support and commitment from senior management for ethical
business practices and corruption prevention (tone from the
Written policies tailored to the risks faced by an organization
and written in accessible, clear language that is easy for
employees to understand
Dedicated personnel tasked with responsibility and
accountability for compliance
Detailed procedures for dealing with specifically identified
Due diligence on business partners and contractors
Application of the company's anti-corruption program to
Internal controls (financial controls, in particular) and
recordkeeping procedures that are appropriate for the
organization's risk profile
Active communication within the organization and training of
A procedure for detecting and reporting violations or suspected
A procedure for investigating reported violations
Periodic internal (or third-party) reviews and evaluations of
the organization's anti-corruption program
Despite this lengthy list of best practices, compliance programs
are not one-size fits all. Companies must understand the risks that
they face and develop specific and targeted programs and policies
to address that risk. Procedures should be appropriately tailored
to the size, risk profile, nature of operations, and capacity of
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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Under the Income Tax Act, the Employment Insurance Act, and the Excise Tax Act, a director of a corporation is jointly and severally liable for a corporation's failure to deduct and remit source deductions or GST.
Under the Income Tax Act, the Employment Insurance Act, the Canada Pension Plan Act and the Excise Tax Act, a director of a corporation is jointly and severally liable for a corporation's failure to deduct and remit source deductions.
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