Relation Between Compliance and ____-__________

CAUSE AND EFFECT RELATION _______

COMPLIANCE AND ANTI-CORRUPTION

Compliance is today one __ the most important issues ___ undertakings regarding the elimination __ their risk in terms __ causing a corruption. Thus, __________ to local law and _____________ conventions must be at ___ top priority of companies’ __________ plans. In case of _________ of corrupt practices in _________, it causes criminal liability ___ civil liability of the _________ of the company and _______ itself as legal entity. ____, corruption issue is a ______ of compliance and cannot __ evaluated as an issue _________ than an issue of ______ cause and effect relation.

There is not a ______ definition of corruption, which __ accepted by all, but ____________ International defined the corruption __ ‘the abuse of entrusted _____ for personal gain’.1 The issue __ corruption is regulated both __ international and national levels. ______ is a country that _____ tries to combat with __________ problem.

In this regard, Turkey ___ ratified some European, OECD ___ UN conventions that aim __ keep the issue of __________ under control with detailed ___________. European Anti-Corruption Conventions, which ______ also ratified, are as _______;

Council of Europe Criminal ___ Convention on Corruption (CEO ________ Law Convention) which provides ___ coordination in the criminalization __ corrupt actions and compliance __ controlled by Group of ______ against Corruption (GRECO)

Council of Europe Civil ___ Convention on Corruption (COE _____ Law Convention) that provides ___ common definitions of civil ___ and corruption. The Group __ States against Corruption (GRECO) ________ compliance.

Council of Europe Convention __ Laundering, Search, Seizure and ____________ of the Proceeds from _____ and on the Financing __ Terrorism of 8 November 1990 is signed on 28 _____ 2007 which one of __ main aim is to _______________ of money transferring to __________ groups.

Besides, as mentioned above ______ ratified OECD Convention Combating _______ of Foreign Public Officials __ International Business Transactions, the ______ Convention against Transnational Organized _____ and the United Nations __________ against Corruption.

The international conventions that ___ United Nations Convention against __________ and the Council of ______ Criminal Law Convention on __________ and OECD Anti-Bribery Convention _________ the liability of the _______ legal persons for their _______ practices.

1The Transparency International Corruption __________ Index is ranking reports __ countries annually "by their _________ levels of corruption, as __________ by expert assessments and _______ surveys.' or more information:

http://www.transparency.org/whoweare/organisation/faqs_on_corruption/2/

Germany and UK are ___ countries that held this _____ as a serious problem ___ regulated comprehensive legislation on ____ matter. Especially, UK Bribery ___ is the cornerstone concerning __________ on the enforcement of _______ practices of companies that _____ the companies liable for _______ practices of their employees, _______________, agents or subsidiaries. Under ___ scope of the UK _______ Act companies should be _____ that the Bribery Act ___ near global jurisdiction and ____ not distinguish between bribery ___ facilitation payments or big ___ small bribery payments.2

In Turkey, the amendment ____ in the Turkish Criminal ____ No 5237 became a ___________ step in order to ______ practices that constitute bribery. __ the amendment made 2012 ___ definitions of the practices, _____ is deemed as bribery __ given, and private commercial _______ is included to the _____ of the Criminal Code.

According to the report __ Business Anti Corruption 2014, __________ is a commonly encountered _______ both in public and _______ sectors in Turkey.3

In 2013 Transparency International ______, it is stated that ___ clarification on the differences _______ bribe and a gift ______ be perceived and the ____-__________ authorities were supposed to __ ineffective. Additionally, in Corruption __________ Indexes (CIP) that International ____________ prepares annually, Turkey has _____ part in lower levels __ this list regarding the ________ of corrupt practices in ____ public and private sectors. ______ was listed as 54th __ 2012, 53 out of 177 in 2014 and 64 ___ of 175 considering the __________ practice of corruption and __ 2015 reports the ranking __ Turkey are speculated to __ lower than 2014 levels. 4

In order to prevent ____ causing corrupt practices, companies ______ be aware of the _________ compliance methods. As to _______ compliance, companies should have _ corporate compliance program, that ______ should involve;

Proportionality; each company’s procedure ______ be in accordance with ___ company’s size and risks;
From top to bottom ________ of a conscious regarding __________ matters of all employees ___ representatives of the company;
Risk assessment that each _______ should evaluate the risks __ the market that it ________ its business;
Providing enough resources to ______ a compliance program and __ train both employees and _______________ of the company;
Due diligence; to be _____ of the fact that ___ are in the management ________ of the company and ___ are the business partners __ that company; 2- The Business Anti-Corruption ______ is a government-sponsored one-stop ____ for anti-corruption compliance resource _____ at the business The ______ is supported by the ________ Union; Sweden’s Ministry for _______ Affairs; Germany’s Federal Ministry ___ Economic Cooperation and Development; ___ UK’s Department for Business, __________ & Skills (BIS); the _________ Agency for Development Cooperation (_____); the Austrian Development Cooperation (___); and the Danish International ___________ Agency (Danida). And it __ referenced tool by the __, the OECD, the World ____, IFC and Transparency International. ___ more at:

http://www.business-anti-corruption.com/about/about-this-portal.aspx

3- http://www.business-anti-corruption.com
4- transparency.org/research/cpi
Monitoring and Review that ____ company should monitor its __________ to rules and preferably ______ have a department for __________ the compliance. 5

_______________ in this matter for ______ are to improve data __________ and management of foreign _______ allegations; 6 provide _________ of the corporate compliance ______; pursuant to this, prepare ________ programs in companies for _______________ and employees; improve the ___________ both in criminal and _____ perspective of non-compliance and ______ more effective monitoring authorities.