An effective compliance program must constantly evolve and be evaluated to ensure the company is addressing current risks and expectations. The Group actively monitors resources such as Transparency International’s Corruption Perceptions Index (CPI) to understand the key compliance risks in the places where it does business. In 2018, the company additionally engaged with an external partner to develop a more detailed risk map summarizing the most significant risks in its various locations, including those related to recent changes in the regulatory landscape.
Key compliance issues, including anti-corruption, antitrust, fraud, discrimination and other compliance risks, have long been included in annual enterprise risk assessments. In 2018, the Group began making plans to supplement these activities with dedicated, in-depth compliance-specific compliance risk assessments, which are expected to begin in 2019.
Key risks identified through these processes are communicated to senior leadership on a regional and global basis. Controls are implemented to address critical risks, including corruption risks (such as risks related to facilitation payments, gifts and entertainment, money laundering, and political contributions) in high-risk locations. These controls are carefully considered and strategically implemented to effectively counter significant risks without placing an undue burden on Bridgestone’s business.
The effectiveness of key controls, including those related to fraud, corruption and money laundering, are reviewed within the scope of periodic enterprise audits. In the spirit of continuous improvement (kaizen), processes and controls are frequently reviewed and optimized. Bridgestone’s new global compliance structure has created many opportunities for reviewing existing processes, identifying best practices and gaps, and implementing enhancements.
Similarly, the global compliance framework creates opportunities for reviewing and optimizing policies related to key compliance risks. When preparing the new Bridgestone Code of Conduct, the company's Global Compliance team considered the effectiveness of existing regional policies and codes of ethics and sought to address any existing gaps. The Code is a living document, and the global team will continue this practice of periodically reviewing its effectiveness and adjusting it, or the compliance program more generally, as needed to meet our goal of maintaining a best-in-class compliance program.