Empowering Integrity. Building Trust.

• What a conflict of interest is: actual, potential and perceived, and why perception alone can damage trust.
• Where conflicts come from: financial interests, family and close relationships, outside roles, gifts and hospitality, and moves between employers.
• Declaring well: when to declare, what to disclose, and keeping declarations current at joining, every year and whenever circumstances change.
• Managing a declared conflict through recusal, reassignment, approvals and monitoring, recorded so the decision can be defended later.
• The red flags reviewers look for, illustrated with anonymised cases from BDI investigations.
• Your organisation's own policy and declaration process, built into the session.

Built onOECD guidance on managing conflict of interestISO 37301 compliance management systemsISO 37001 anti-bribery management systems

• What counts as moonlighting, dual employment and a side business, and when outside work is acceptable.
• The risks: conflicts of interest, misuse of working time, and leaks of confidential information and intellectual property.
• The position in India: what employment contracts, service rules and company policies typically require.
• Remote and gig work: how to assess an outside engagement before taking it on.
• Declaring outside work and seeking approval, and the consequences when it is not declared.
• Anonymised case studies of undeclared parallel employment uncovered in investigations.

Built onOECD guidance on managing conflict of interestISO 37301 compliance management systemsYour code of conduct and employment terms

• Which transactions are in scope: loans, investments, guarantees, payments, gifts and favours involving vendors, customers, dealers or people connected to them.
• Who counts as a connected person: relatives, close associates and the entities they control.
• Why these transactions create risk: undue influence, kickbacks disguised as loans or investments, and conflicts of interest.
• Related-party rules for companies: approvals and disclosures under Companies Act s.188 and, for listed entities, SEBI LODR Reg. 23.
• Declaring, seeking approval and keeping records that stand up to audit.
• Red flags and anonymised cases from BDI investigations.

Built onIAS 24 / Ind AS 24 Related Party DisclosuresCompanies Act, 2013 s.188 and SEBI LODR Reg. 23ISO 37001 due diligence on business associates

• What bribery is, whether paid directly or through intermediaries, including facilitation payments.
• Gifts, hospitality, donations and sponsorships: what is acceptable, and how to record and approve them.
• Third parties: due diligence on agents, distributors and consultants, and the red flags that call for escalation.
• The law that applies: the Prevention of Corruption Act, 1988 (including the liability of commercial organisations under s.9), the US FCPA and the UK Bribery Act 2010.
• What an adequate anti-bribery programme looks like: tone from the top, risk assessment, controls, training, speak-up and monitoring.
• Dilemmas and case studies drawn from BDI investigations.

Built onISO 37001 anti-bribery management systemsUN Convention against Corruption (UNCAC)OECD Anti-Bribery ConventionUK Ministry of Justice guidance on adequate procedures

• What amounts to sexual harassment at work under the POSH Act, 2013, including situations online, off-site and on work travel.
• Who the Act protects, and how many organisations extend their policies to every employee.
• How to raise a complaint, how confidentiality works, and protection against retaliation.
• The Internal Committee: its composition, the inquiry procedure and the timelines (inquiry within 90 days, the employer's action within 60 days).
• What managers and colleagues should do when they see or are told about harassment.
• The employer's duties: policy, awareness, the Internal Committee and annual reporting.

Built onPOSH Act, 2013 and its RulesILO Violence and Harassment Convention, 2019 (No. 190)ISO 45003 psychological health and safety at work

• What unpublished price-sensitive information is, with everyday examples: results, mergers, major contracts and leadership changes.
• Who is an insider, a designated person or a connected person.
• Trading windows, pre-clearance of trades and the restriction on contra trades.
• Sharing UPSI only for legitimate purposes, maintaining the structured digital database, and handling leaks.
• Disclosures, penalties and how SEBI enforces the regulations.
• Reporting suspected leaks of UPSI under the whistle-blower policy required by Reg. 9A(6).

Built onSEBI (Prohibition of Insider Trading) Regulations, 2015IOSCO Objectives and Principles of Securities RegulationEU Market Abuse Regulation (for comparison)

• Who the FCPA applies to (issuers, domestic concerns and those acting in the US) and how Indian companies and their staff can come within its reach.
• The anti-bribery provisions: corrupt payments to foreign officials, including payments made through third parties.
• The accounting provisions: accurate books and records, and an adequate system of internal accounting controls.
• The exception for facilitating payments and the defence for reasonable, bona fide expenditure.
• Enforcement by the DOJ and SEC, penalties, and what prosecutors expect of a corporate compliance programme.
• Lessons from enforcement actions, translated into everyday controls.

Built onUS Foreign Corrupt Practices ActDOJ and SEC Resource Guide to the FCPADOJ Evaluation of Corporate Compliance Programs

• Why the Digital Personal Data Protection Act, 2023 matters and who it applies to, including processing outside India in connection with offering goods or services in India.
• The key roles: data principal, data fiduciary, data processor, consent manager and significant data fiduciary.
• Lawful processing: notice and consent, and the legitimate uses that do not need consent.
• Individuals' rights: access, correction and erasure, grievance redressal and nomination.
• Organisations' duties: security safeguards, breach notification and limits on how long data is kept.
• The Data Protection Board of India and penalties of up to ₹250 crore.

Built onDPDP Act, 2023 and DPDP Rules, 2025OECD Privacy GuidelinesGDPR principles (for comparison)

• Building the data inventory: what personal data you hold, where, why and for how long.
• Notices and consent that meet the DPDP Rules, with consent records and easy withdrawal.
• Security safeguards, and contracts with the data processors who handle data for you.
• Breach response: detection, notice to the Data Protection Board and to affected individuals, and the evidence to keep.
• Handling rights requests and grievances within the prescribed timelines.
• A phased plan to the compliance date set by the DPDP Rules, with owners and evidence for each step.

Built onDPDP Act, 2023 and DPDP Rules, 2025ISO/IEC 27001 information securityISO/IEC 27701 privacy information management

• What UCPMP 2024 requires: no gifts or personal benefits, limits on samples and brand reminders, and CME and CPD events held in India with spend disclosed.
• The executive head's annual self-declaration, and the evidence that should sit behind it.
• How to test controls over HCP engagement: camps, CMEs, samples, consultancy fees and field-force claims.
• Data analytics and red flags across expense, CRM and event records.
• Complaints to an Ethics Committee for Pharma Marketing Practices, and how to respond.
• Designing corrective actions that close the gaps the review finds.

Built onUCPMP 2024, Department of PharmaceuticalsIFPMA Code of PracticeUS Sunshine Act (for US operations)