Design and implementation of mitigation plans (anti-corruption tools and measures)

Implementation of mitigation plan

The diagnosis should determine the selection of measures suitable to mitigate the identified risks. See teh table below for how exemplary measures could constitute a mitigation plan.

Table: Exemplary basic mitigation plan

Risk # Risk Measure Ownership Support Deadline Status
2.1 Manipulation of key documents Increasing Internal Audit resources Director of Human Resources  Internal Audit 12/31/2014 Application process initiated (schedule met)
2.2 Manipulation of key documents Sophisticated checklist for audits Internal Audit Accounting department 09/30/2014 Accounting is reviewing checklist (behind schedule)
1 Falsification of invoices  Sounds Billing System Finance department IT department 10/31/2014 IT is piloting new software (schedule met)
4          

The selected mitigation measures should be put into a detailed, time-bound, action plan that can be monitored. This plan needs to designate who will take responsibility (or “ownership”) for each measure. Ideally, there should also be at least some degree of support for implementing the risk mitigation measures.

The mitigation plan then serves as a dynamic guide throughout the implementation process, and needs to be continuously updated to track the course of each measure.