Ethics

Ethics is the foundation on which the edifice of good corporate governance rests. Ethics is what we consider as right and wrong in terms of rights, obligations, and benefits to society, fairness, or specific virtues. Ethical standards also cover virtues of honesty, compassion, and loyalty. These standards are adequate as they are based upon consistent and well- founded reasoning. Therefore it is necessary to constantly examine one’s standards to ensure that they are reasonable and well founded.

Practical knowledge of Anti-Bribery Legislations like the US FCPA, UK Bribery Act, Indian Prevention of Corruption Act and Prevention of Money Laundering Act, Companies Act etc. and their compliance. This training can be carried out in the following two ways:

Compliances

Customised anti-bribery compliance task lists capturing the organisations anti-bribery compliance obligations. This task list is integrated with the organisations Code of Conduct (CoC) and anti-bribery policy, thereby reiterating the provisions of the CoC and policy and spreading awareness. This data is uploaded on the anti-bribery online tool designed and developed by Trosa.

Classroom Training

Customized classroom training(s) for the Board, CXO/CFO, Frontline Representative as well as all other concerned employees.

Web Based Training

In order to ensure training of large number of employees, Trosa also offers a web-based training, followed by self-certification depending on passing of the test at the end of the training.

Advisory

Assistance to clients on how to comply with their anti-bribery obligations, and how to mitigate the associated risks. Advice on the anti-bribery terms in contracts sought to be entered into by the organisation.

Trosa has the capability to advise its clients on various policies, including drafting the Code of Conduct, Anti-Bribery Policy and Gifts and Hospitality Policy. Support in terms of sensitization and spreading of awareness on these policies to make them an integral part of the culture of the organisation.

Drafting

Trosa team to interact with various function heads (including HR, Finance, and Procurement) in the organisation and the Board to draft a Code of Conduct and relevant policies for the organisation that is in clear and unambiguous terms. Update of the Code of Conduct and relevant policies also form a part of this service.

Training

Training on the Code of Conduct and relevant policies according to us is equally as most important as having a properly drafted Code of Conduct and relevant policies. The training on the Code of Conduct and relevant policies integrates the provisions of the Code of Conduct with relevant provisions of laws including the US FCPA, UK BA, PCA and PMLA.

Self-Certification

The self-certification will be of the relevant provisions of the Code of Conduct and relevant policies which will be broken down into compliance tasks. Every individual of the organisation, as may be identified will be required to submit an undertaking of having read and understood the provisions that have been captured.

Implementation

No Code of Conduct is effective without adequate implementation mechanisms. Trosa assist in setting up or revising mechanisms to foster sharing of the values and mission alongside efficient implementation and periodic reviews.

In view of the increasing regulatory and enforcement activities, the practice of enforcement agencies to conduct surprise search and seizures (Raid), it is imperative for an organization to prepare itself. This can be provided through the following three ways:

• Mock Audit Trosa with its team of lawyers and Enforcement Officers is well equipped with the expertise to carry out mock audits of organizations and advise them to plug gaps in the system.
• Prevention and Training Similarly, Trosa is ideally positioned to advice and prepare its clients on how to handle a Raid through its intensive training package, mock drills and do`s and don’ts.
• Support during Raid With its pan India presence, Trosa is well placed to immediately provide its specialized attorney support on receipt of any communication for assistance at the onset of a Raid.
• Post-Raid Support Undertake an in-depth review of the documents, assets and other evidence seized during the Raid and offer relevant legal advice for damage control. Trosa has also the required skill-sets to tender legal advice to deal with the concerned enforcement/regulatory bodies and quasi-judicial authorities.