Course Outline
1. Where is the red line? (30 min, activity)
Participants receive cards depicting real situations from business operations (a gift from a subcontractor, an invitation to a match from a supplier, hiring a mayor's nephew in a city where the company operates, etc.). Each participant places the cards on a physical axis in the room: acceptable / grey area / prohibited. The resulting map becomes the starting point for the day.
2. Bribery and Corruption
- 2.1 Active and passive bribery, influence peddling, and facilitation payments
- 2.2 Specifics of the utilities sector: interface with local authorities, public tenders, permits and licenses, relationship with contracting city halls
- 2.3 Legislation:
- Law 78/2000;
- Penal Code art. 289–292 and 308
- Sapin II;
- Law 361/2022;
- GDPR and Labor Code for investigations;
- Veolia policies and procedures.
- 2.4 Workshop
3. Conflict of Interest: The Most Underestimated Risk (75 min)
- 3.1. Real, potential, and apparent conflicts
- 3.2 Declaration versus effective management
- 3.3 Sector-specific case law: employees with construction companies on the subcontractor list, relatives in local administration, secondary activities of technical staff
- 3.4 Workshop
4. Third-party Due Diligence
- 4.1 Classifying third parties by risk level
- 4.2 Red Flags
- 4.3 Verification sources and clauses
- 4.4 Continuous monitoring vs. one-off monitoring
5. Investigating a Fraud Case (90 min)
- 5.1 Structure of the investigation
- 5.2 Classic errors
- 5.3 Workshop
6. Workshop
A timed simulation in which each team simultaneously manages 4 situations that arrive staggered throughout the exercise.
The exercise integrates, in a single scenario, all the topics covered during the day.
Requirements
- Experience in compliance, anti-fraud, or related fields.
- General knowledge of internal compliance policies and procedures.
- Laptop – recommended for practical exercises.
Testimonials (2)
The exercises were great — they helped me get back “on the field.”
Lilia Boico - PUBLIC
Course - AML/CTF Governance and Risk Oversight Training
Practical part of the training was very good structured and useful
