2. This leaflet is intended especially for telling what Awara Purchase Manager can do for the company controller
and other compliance officers. It serves as a complement to our standard Awara Purchase Manager brochure.
Awara Purchase Manager is an electronic invoice processing system that enables the control of each purchase
invoice from initiation to payment. It brings efficiency and order into the process of monitoring purchases and
their payments.
But Awara Purchase Manager does not only bring paperless efficiency. It comes with a lot of other value-
added features: • The system enables real-time control of the whole purchase process. • It can be made to
communicate automatically with your on-line banking system, feeding the system with payment orders and
receiving return feedback data of the payments. • It enables automatic transfer of purchase data to the financial
and tax accounting systems. • It enables correct accounting of accruals in IFRS, GAAP, and other international
standard reports. • It enables transparent management reporting on all aspects of accounts payable.
By using Awara Purchase Manager the controller will have easy access to all data that is necessary for
approving a payment and monitoring purchases. Together with the scanned invoice you can readily see, for
example, to what contract the invoice refers; who initiated the purchase; who approved it; what limits they had;
what was delivered and when. After delivery the system helps to track the receipt of all supporting documents
that are needed according to Russian laws.
With Awara Purchase Manager you can put in place an efficient financial administration function that meets
the highest international standards. And this is the only system globally that is especially tailored to meet the
needs of the controller to ensure compliance with anti-corruption laws such as the US FCPA, UK Anti-Bribery
Act, and the laws based on the OECD Convention on Combating Bribery.
Below follows a list of features that Awara Purchase Manager enables especially from point of view of efficient
control.
COMPLIANCE WITH INTERNAL POLICIES
Control of procurement processes.
All purchases have to be recorded in the system. no payments will be executed without following this
rule and all the processing steps.
• The system will allow the company to set a general
rule that all purchases will have to be duly recorded • This functionality serves as the fundament for
in the system from their initiation with the control that implementing a proper control system.
3. Catalogue of approved suppliers.
• Enables to establish a catalogue of approved suppliers.
AWARA PURCHASE
• System may restrict purchases to be done only from
MANAGER
the choice of approved suppliers.
• This feature helps to control that suppliers are chosen
lets you control
by management decisions as opposed to ad hoc
decisions on lower organizational level. Such ad hoc
your work and values
decisions may interfere with several organizational
goals, such as quality management, partnership
programs, best practices, discount programs and
legal compliance. Ad hoc supplier choices may provide
opportunities for personal gain or be initiated in
connection with the aim to give an unlawful gain to a
supplier or a third party.
Authorized Initiators.
• System allows to restrict the initiation of a purchase
of defined type to pre-determined initiators (persons
that have the right to initiate a purchase).
• This feature allows to red flag suspicious purchases
when person that is not connected with the given
business issue interferes in the process.
Authorized Approvers.
• The main actors in procurement processes are the
one who initiates the procurement (initiator) and the
one who approves the procurement (approver). Often
it makes sense to keep these obligations separated.
• System enables the restriction of the rights to approve
a purchase to a pre-determined list of authorized
approvers.
• The approvers can be assigned approval rights for
determined types of purchases and they can be limited
in their approval rights, for example, what comes to
monetary value of the purchase, periodicity (approve
one-time transactions as opposed to periodic
transactions), and choice of supplier.
DETECTION OF IRREGULARITIES
The history of each purchase can be monitored by various
search criteria, for example:
• By following any of the features in the process in view
of the integrated system showing the life-cycle of each
purchase from initiation through payment to delivery.
• By verifying who was the initiator, who was the
approver, what were the relevant levels of
authorization.
• By supplier verifications. Has the supplier been officially
approved according to the procedures and criteria for
choice of suppliers? - Comparison of similar purchases
from various suppliers; initiator and approver behaviors
in respect to various suppliers.
• By monitoring deliveries to purchases. The system
links all the documentation/records of deliveries that
pertain to a certain purchase which enables controlling
that the deliverables have actually been received with
due quality.
6. COMPLIANCE WITH ANTI-CORRUPTION LAWS
Awara Purchase Manager has been especially tailored
to meet the needs of the controller to ensure compliance
with anti-corruption laws such as the US FCPA, UK Anti-
Bribery Act, and the laws based on the OECD Convention
on Combating Bribery. The anti-corruption, or anti-bribery,
laws of developed countries are becoming increasingly
severe and pose a new kind of compliance challenge
for firms. Of particular significance for the controller is
the fact that not only bribing is a criminal offense but the
failure to prevent the organization from bribing is also
an offense. This is explicitly stated in the new UK Bribery
Act of 2010 (Section 7, UK Bribery Act).
This is a strict liability and when charged with a particular
case of bribery the only defence is that the firm can show
that it had in place adequate procedures designed to
prevent its employees or other persons associated with
the firm from undertaking acts of bribery.
In practice the company management has to create
adequate procedures for preventing bribery also under
the US FCPA. And the same follows from the OECD
Convention.
Six Principles defining Adequate Procedures.
According to the guidelines to the Bribery Act published
by the UK Ministry of Justice (and similarly with the
OECD Convention) the ‘adequate procedures’ are defined
by 6 principles (and similarly with the OECD Convention):
Proportionate procedures - The organization's procedures
are to be proportionate to the bribery risks it faces and
to the nature, scale and complexity of the organization's
activities. The procedures are to be designed to mitigate
identified risks and to prevent deliberate unethical conduct. fostering a culture in which bribery is never acceptable.
They have to be clear, practical, accessible, effectively
implemented and enforced. Risk Assessment - The organization must assess the
nature and extent of its exposure to potential external
Top level commitment - The top management is to be and internal risks of bribery. The periodic risk assessments
committed to a zero tolerance of bribery and actively include: country risk, sectoral risk, transaction risk,
pursue a strategy of prevention including by means of business opportunity risk and business partnership risk.
7. Due diligence - The organization should in order to mitigate identified bribery risks apply due diligence procedures,
taking a proportionate and risk based approach, in respect of persons who perform or will perform services for or
on behalf of the organization.
Communication ( including training) - The organization shall ensure that its bribery prevention policies and procedures
are embedded and understood throughout the organization through internal and external communication, including
training, that is proportionate to the risks it faces.
Monitoring and review - The organization shall monitor and review procedures designed to prevent bribery by persons
associated with it and makes improvements where necessary.
Financial Software for Implementing the Bribery Prevention Policies.
A central role among the required procedures is assigned to the systems that actually implement the financial and
commercial controls such as adequate bookkeeping, auditing, and approval of expenditure. Awara Purchase Manager
is precisely such a system that enables these controls while ensuring transparency of transactions and disclosure
of information, as it has been described above.
Awara Purchase Manager will help to implement proper decision making procedures and an orderly delegation of
authority. A proper system for preventing bribery needs to enable the control of separation of functions and the
avoidance of conflict of interests. These functions are achieved by Awara Purchase Manager.
Other Necessary Procedures.
Together with other specialists we can complement our software solution with offering full advice in putting in place
all the necessary elements of a proper system for preventing bribery. These elements comprise, inter alia, the
following procedures: the actions to show top-level commitment; risk assessment procedures; due diligence
procedures; various policies, such as the policy for provision of gifts, hospitality and promotional expenditures,
charitable and political donations; recruitment and other HR policies; policies for governing the relations with
consultants, advisors, agents and other associated persons; enforcement and sanctions policies; communication
policies.
Tel. + 7 495 225 3038
Moscow, St. Petersburg , Tver, Yekaterinburg, Kiev, Helsinki
www.awaragroup.com
8. Created by Awara Marketing with Kai Venäläinen
AWARA PURCHASE MANAGER
THE COMPLIANCE TOOL
FOR CONTROLLERS
www.awaragroup.com