In this article we will discuss the third fundamental element under the National Anti-corruption Commission (NACC)’s guidelines, namely “enhanced and detailed measures for high-risk and vulnerable areas.”
In our previous article in the healthcare transaction series, we highlighted the need to review a target’s supply chain as one of the key areas and issues that one should pay attention to when carrying out a due diligence investigation on a healthcare & life sciences (HLS) target. This exercise in revisiting one’s supply chain in light of the COVID-19 pandemic and emerging industry trends, including (among others) digital transformation, will ensure that the company’s supply chain is resilient, compliant, and ready to meet the challenges and opportunities in the HLS industry.
In this article, we will discuss the second fundamental element under the NACC’s guidelines, which is “the risk assessment to effectively identify and evaluate exposure to bribery.
In our previous article (link), we discussed the benefits for a company that has appropriate internal control measures. For the second article of the series, we will discuss the first fundamental element under the NACC’s guidelines, which is “the companies’ internal control measures should be strong, visible policies and supported by top-level management to prevent bribery.”
Under the Organic Act on Counter-Corruption, B.E. 2561 (2018), companies operating in Thailand must put in place “appropriate internal control measures” that comply with the National Anti-Corruption Commission’s (NACC) guidelines. Failure to do so carries a penalty of a fine from one to two times the value of the damage caused, or benefits gained, as a result of the violation.