PROTIVITI FLASH REPORT

Size: px
Start display at page:

Download "PROTIVITI FLASH REPORT"

Transcription

1 PROTIVITI FLASH REPORT California Law Requires Companies to Disclose Efforts to Ensure Supply Chains Are Free of Slavery and Human Trafficking February 6, 2012 The California Transparency in Supply Chains Act ( Act ) became effective on January 1, The objective of this social policy-driven legislation is to eliminate slavery and human trafficking from product supply chains of companies operating in California. Its focus is on increasing transparency by requiring companies to disclose their efforts to ensure their supply chains are free of these illegal activities. This Flash Report discusses the requirements of the law and offers suggestions on what companies subject to the Act should be doing. The Act s Requirements The Act requires retail sellers and manufacturers doing business in [California] to disclose their efforts to eradicate slavery and human trafficking from their direct supply chains for tangible goods offered for sale. It applies to retailers and manufacturers operating in California with annual worldwide revenues of more than $100 million. It is estimated by the California Franchise Tax Board that there are 3,200 major companies trading or based in California that will be affected by the law. A company is deemed to be doing business in California if any of the following conditions are met: The company is organized or commercially headquartered in California. The company s sales in California for the applicable tax year exceed $500,000 or 25 percent of its total sales, whichever is less. The company s real and tangible personal property in California exceeds $50,000 or 25 percent of the company s total real and tangible personal property, whichever is less. The company s paid compensation amount in California exceeds $50,000 or 25 percent of its total paid compensation, whichever is less. Those companies subject to the Act s disclosure requirements shall, at a minimum, communicate to what extent, if any, the company performs each of the following: Verifies whether risks of human trafficking and slavery in product supply chains are evaluated and addressed, including whether such verification is conducted by a third party. Conducts audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in direct supply chains, including whether or not the audit was performed unannounced by an independent party.

2 Requires direct suppliers to certify that materials incorporated into their products comply with the laws regarding slavery and human trafficking of the country or countries in which they do business. Maintains internal accountability standards and procedures for addressing employees or contractors failing to meet company standards regarding slavery and trafficking. Provides training on human trafficking and slavery to company employees and management with direct responsibility for supply chain management, with emphasis on mitigating risks within product supply chains. The Act s focus is on transparency, and therefore, it does not require implementation of any of the above steps, only disclosure on whether or not such steps are carried out. In addition, the Act does not require companies to stop working with suppliers involved with human trafficking and slavery. That said, failure by a company to disclose its efforts with regard to the above matters could result in the state attorney general taking action to ask for injunctive relief, meaning requiring the company to comply. Typically, a party that fails to comply with an injunction faces criminal or civil penalties, which result in damages or sanctions. In this case, that could mean a cessation of the right to do business in California. In addition, the Act makes it clear that it does not limit any remedies available for a violation of any other state or federal law. To comply with the law, each retailer and manufacturer must post a conspicuous link to its disclosure on the home page of its website as well as make the disclosure available in writing upon request. In the rare situation that a company doesn t have a website, the written disclosure must be made available to consumers within 30 days after the company receives a request for it. Nothing in the law protects companies from additional liability, such as false advertising or misrepresentation, under other state or federal laws. Impact of the Act We are unable to determine if anyone has estimated the potential cost burden the Act might pose on companies doing business in California. That s just as well because the actual cost is driven more by a specific company s circumstances, making generic estimates meaningless. The cost drivers include, among other things, the extent of a company s operations in high-risk countries, the number of audits required to verify compliance, the nature of those audits (e.g., whether they are based on self-assessments through the Supplier Ethical Data Exchange [Sedex] or site visits by third-party auditors), the extent of remediation efforts required, and whether changes in supplier relationships are required. 1 While California may be the first state to pass this legislation, others are likely to follow. In addition, a bill was introduced in Congress last year, modeled after the California law. If passed, the bill would require publicly traded companies to disclose in their annual reports to the Securities and Exchange Commission all measures taken to counter forced labor, human slavery, trafficking, and child labor within companies supply chains. Therefore, federal legislation is possible. Interest is not limited to the United States. Efforts to combat human trafficking and slave labor have placed growing pressure on large, global companies throughout the world to collaborate towards eradicating trafficked and forced labor from their supply chains. Thus we can expect companies worldwide to become more transparent about their efforts to eliminate all forms of human rights abuses contributing to the products they manufacture and sell. 1 Sedex is a non-profit organization dedicated to driving improvements in responsible and ethical business practices in global supply chains, including labor standards, health and safety, the environment, and business integrity. Protiviti 2

3 Given the complexity of company supply chains and the multitude of contractors, recruiters, suppliers and other parties used throughout a production process, there can be significant risks to companies from human rights issues. In many respects, this legislation should stimulate increased company awareness of these risks, including knowledge of the ways that traffickers may use a company s products, services, or workplaces in connection with their illegal activities. Failure to consider and address these risks may result in public protests, business interruption, and potential litigation, all of which can lead to adverse publicity, loss of consumer trust, reputation damage, brand erosion and impairment in shareholder value. We are aware that many companies have questions and uncertainty regarding the new law. These were evident in the findings of Protiviti s soon-to-be-released 2012 Internal Audit Capabilities and Needs Survey. In the study, internal audit executives and professionals in the manufacturing industry (from organizations based throughout the United States, as well as in other countries) cited the new California supply chain law as the top area in need of improvement, and thus a top priority for their organizations. Companies will want to consult with legal counsel on these questions, particularly if the California attorney general does not provide guidance on the Act s provisions. Questions include the following: (1) Presumably the reference to direct supply chains is a reference to Tier 1 suppliers. What about Tier 2, Tier 3 and other suppliers further up the chain, i.e., suppliers of a direct supplier? (2) What is meant by materials incorporated into products? Is there, or should there be, a materiality threshold of some kind, or does this provision cover everything from screws to large component parts? What if a direct supplier has issues in its supply chain and is unaware of them, and the tainted materials are ultimately incorporated into the company s product? (3) How does this disclosure fit within the company s broader corporate social responsibility disclosures? (4) How does the state define doing business in California for organizations without physical facilities in the state? For example, does a manufacturer with no operations (i.e., neither physical facilities nor sales) in California but a supply chain that runs through the state via shipping ports in Long Beach have to comply? What about sales to California residents on the Internet? (5) If a manufacturer or retailer is not in compliance, how long do they have to address gaps before being subject to action by the California attorney general? (6) What if a direct supplier of a company engages in trafficking and slavery in its supply chain but alleges that such activities do not affect the company s products? Will issues arise with respect to traceability of such activities to the specific materials they taint to ensure no tainted materials are supplied to the company and incorporated into its products? (7) What if a company with lines of business doing business in California has issues with respect to specific products of a specific line of business that is not doing business in any way, direct or indirect, in California? Do the disclosure rules apply? (8) How will the California attorney general monitor and enforce compliance with the Act? (9) Will this legislation, and others like it, create exposure to litigation from victims of human trafficking for actual, compensatory and punitive damages from companies failing to take appropriate steps to eliminate slavery and trafficking from their supply chains? Protiviti 3

4 (10) Will similar laws be enacted in other states, at the federal level or in other countries? If so, when are such laws expected to go into effect? The above questions are illustrative only and are not intended to be all-inclusive. Steps for Companies to Consider for Purposes of Compliance With respect to compliance, companies need to read the law carefully and consult with their legal counsel. This is particularly important because of the lack of detailed guidance and the questions executives may have in terms of the applicability of the Act to their companies circumstances and the best approach to comply with the Act s provisions as well as any other related laws and regulations to which the company may be subject. With the above caveat, we provide some suggestions below for companies and their counsel to consider: Adopt appropriate human rights standards: Develop a policy statement that clearly articulates the company s standards in regards to human rights issues and its position that its reputation, brand, products and services not be associated with human rights violations. For example, some companies give recognition to the Universal Declaration on Human Rights. 2 Companies are advised to seek help in identifying the standards they use. Acknowledge extent of ability to influence behavior: One major global company asserts in its disclosure that its commitment to human rights must consider the strength and sphere of its influence on its business partners and others in the context of its relationship with those parties and the nature of its transactions with them. For example, the ability to influence behavior is strongest when dealing directly with employees and direct business partners such as suppliers and joint venture partners in which a company holds a controlling interest. The ability to influence positively the communities in which a company s plants and businesses are located, as well as governments, depends on many factors, e.g., whether the government is a customer, the substance and enforcement of existing local laws, the human rights issue in question, and the extent of the company s operations within a given country. The point is that human rights involve complex issues and a given company, by itself, may have limited influence in specific circumstances involving human rights abuses. Articulate roles and responsibilities: Specify who is responsible and what is expected of them. This definition of responsibility starts at the top, with a designated senior executive, and cascades downward to the business units, functional leaders, compliance officers and the broader employee group. Acknowledge the standards: Require each supplier to commit to the company that they adhere to the standards. Supplier agreements: Require suppliers to accept the relevant principles set out in the company s human rights standards by incorporating them in the supplier agreement. The willingness of suppliers to accept these principles should be an integral part of the company s supplier selection and evaluation process. Assess risk: Periodically review the supplier base and assess all potential suppliers to determine the level of risk associated with each insofar as compliance with the company s standards is concerned. This process may entail segmenting direct, material suppliers into risk categories (i.e., low, medium and high) based on management s knowledge of the industries and the inherent risks of the country of origin. For example, one company selects high-risk suppliers using a country-based risk approach based on its country index for sustainability risks 2 Available at Protiviti 4

5 derived from risk assessments of various international indices such as the Corruption Perception Index published by Transparency International. Another company assesses risk by considering such factors as security of personnel and assets, potential for violence, historical human rights records, and the existence or non-existence of rule of law. For example, regular supply chain risk assessments could be directed to evaluating high-risk sectors, regions and commodities frequently associated with human rights violations. The U.S. State Department s Trafficking in Persons Report may be useful in this regard, as it ranks countries on anti-trafficking measures. 3 In addition, the U.S. Department of Labor s List of Goods Produced by Child Labor or Forced Labor (available at cites goods from countries that the agency believes are produced by child or forced labor in violation of international standards. Verify compliance: Conduct audits of higher risk suppliers, on either an announced or unannounced basis, to ensure full compliance. Depending on the relative risk by supplier, a company may choose to rely on supplier acceptance of its policies and standards or conduct on-site audits (by either company personnel or through independent auditors). With respect to the latter, if a company conducts social accountability audits, it may consider adding a section addressing anti-slavery and human trafficking questions. Through an addition of this nature, its internal auditors (or independent auditors or third-party consultants, if any are used) can evaluate whether manufacturers have written policies and procedures in place addressing the specific areas in question. Another option is to verify compliance through participation in Sedex. With respect to Sedex: If a supplier is a member, it may complete a self-assessment questionnaire and share it with multiple customers, along with audit reports and certifications. By allowing suppliers to share the same data with many customers, Sedex helps reduce the need for multiple audits, increasing cost-effectiveness and allowing parties to concentrate on making the necessary improvements. Regardless of the verification procedures, it is important that management focus on ensuring the right questions are being asked of high-risk suppliers. Request improvements: The above activities enable the organization to establish a baseline for driving improvements. The data compiled from supplier audits, questionnaires and other input are used to determine whether specific suppliers meet the company s requirements or whether the company needs to define further development measures and goals in collaboration with the supplier. Action plans drawn up with suppliers should be documented centrally and their implementation tracked to ensure progress according to an agreed-upon timetable. As companies within an industry gain experience and disclose issues, pressure will mount on suppliers to take corrective action. This, of course, is exactly what the proponents of the Act had in mind. The idea is that through collaboration with suppliers, companies can drive opportunities for improvement. Conduct training: Consider training procurement employees to identify and respond to supply chain risk issues involving human rights. Training content should be updated regularly and adapted to the needs of the targeted personnel. Respond to noncompliance: Determine protocols for situations in which it is determined that a supplier is not in compliance with the company s policies and standards. For example, should the company provide the supplier with the opportunity to remedy the potential non-compliance through the implementation of a corrective action plan? If so, what are the requirements to verify the remediation plan through a subsequent audit? How much time should the supplier be allowed to remediate the condition before it is eliminated from the company s supply chain? 3 Available at Protiviti 5

6 What about serious infringements, i.e., should they result in immediate termination of supplier contracts? Disclose progress: Specify the steps taken in response to the requirements of the law. Disclose the nature of the company s policies and standards, the scope of its review of its supplier base, the scope of its audits and other verification activities, the results of such activities, the extent of training and acknowledgement programs, and other collaborative and due diligence activities to comply with its obligations under the law. Other practices: Some companies disclose that they do not maintain any long-term contracts or commitments with suppliers and are therefore free to take their business elsewhere should a supplier fall short of their expectations. Some legal experts have advised retailers and manufacturers as a best practice to require suppliers to verify compliance with human trafficking and slavery laws in the countries in which they operate. We are aware of some companies extending the scope of their review to material, indirect suppliers (tier 2, tier 3, etc.). Summary Prior to the Act s enactment, companies only had to issue disclosure around such matters as child labor. Now the net is cast more broadly. It s easy to think that slavery is a problem that only touches impoverished people in Third World countries. But nearly every American has a direct personal connection. The problem of human trafficking and slavery is so widespread, it would be virtually impossible to find a home, school, church or business that doesn t contain slave-tainted goods. It could be coffee, cocoa, computers, cell phones, cars or clothing. The sad reality is that many goods are still manufactured in sweatshop slavery conditions, or with raw materials that are farmed or mined by slaves. In addition, according to the National Human Rights Center in Berkeley, California, forced laborers exist in the United States; therefore, it is not just a problem for impoverished nations. The California law is an important step in rooting out these human rights abuses by requiring transparency. Companies failing to fully investigate and disclose these abuses in their supply chain could face significant consequences. In addition, companies that do not undertake sufficient steps to check their supply chains should anticipate investigative journalists to seek out any abuses in their supply chain and exploit them in the media, including vivid descriptions of the working conditions. Protiviti 6

7 About Protiviti Protiviti (www.protiviti.com) is a global consulting firm that helps companies solve problems in finance, technology, operations, governance, risk and internal audit. Through our network of more than 70 offices in over 20 countries, we have served more than 35 percent of FORTUNE 1000 and Global 500 companies. We also work with smaller, growing companies, including those looking to go public, as well as with government agencies. Protiviti is a wholly owned subsidiary of Robert Half International Inc. (NYSE: RHI). Founded in 1948, Robert Half International is a member of the S&P 500 index. Contacts Carol Beaumier Richard Childs Sharon Lindstrom Protiviti Inc. An Equal Opportunity Employer. Protiviti is not licensed or registered as a public accounting firm and does not issue opinions on financial statements or offer attestation services.

Benchmark Methodology Information & Communications Technology (ICT)

Benchmark Methodology Information & Communications Technology (ICT) Benchmark Methodology Information & Communications Technology (ICT) Indicator Name 1. 0 C o m m i t m e n t a n d G o v e r n a n c e 1.1 Awareness and The company publicly demonstrates its Commitment

More information

The California Transparency in Supply Chains Act

The California Transparency in Supply Chains Act The California Transparency in Supply Chains Act A Resource Guide 2015 Kamala D. Harris, Attorney General California Department of Justice The California Transparency in Supply Chains Act A Resource Guide

More information

Modern Slavery Act 2015

Modern Slavery Act 2015 Knowledge Insight Modern Slavery Act 2015 The Modern Slavery Act came into Force in 2015. This insight gives an overview of the Act; focusing on the impact on Supply Chains and the role of Procurement

More information

APEC General Elements of Effective Voluntary Corporate Compliance Programs

APEC General Elements of Effective Voluntary Corporate Compliance Programs 2014/CSOM/041 Agenda Item: 3 APEC General Elements of Effective Voluntary Corporate Compliance Programs Purpose: Consideration Submitted by: United States Concluding Senior Officials Meeting Beijing, China

More information

Payment Card Industry Data Security Standard (PCI DSS)

Payment Card Industry Data Security Standard (PCI DSS) Payment Card Industry Data Security Standard (PCI DSS) WARNING: Your company may be in noncompliance with the Payment Card Industry Data Security Standard (PCI DSS), placing it at risk of brand damage,

More information

PROTIVITI FLASH REPORT

PROTIVITI FLASH REPORT PROTIVITI FLASH REPORT Even Retailers and Consumer Products Manufacturers Must Manage Compliance with the U.S. Foreign Corrupt Practices Act and Other Anti-Bribery Laws May 3, 2012 Recent reports of alleged

More information

Human Rights and Responsible Business Practices. Frequently Asked Questions

Human Rights and Responsible Business Practices. Frequently Asked Questions Human Rights and Responsible Business Practices Frequently Asked Questions Introduction The need for companies to understand and address human rights as a responsible business practice is growing. For

More information

Platform Specialty Products Corporation Foreign Corrupt Practices Act/Anti-Corruption Policy

Platform Specialty Products Corporation Foreign Corrupt Practices Act/Anti-Corruption Policy 1. Introduction. Platform Specialty Products Corporation Foreign Corrupt Practices Act/Anti-Corruption Policy 1.1 Combating Corruption. Platform Specialty Products Corporation, including its subsidiaries,

More information

PROTIVITI FLASH REPORT

PROTIVITI FLASH REPORT PROTIVITI FLASH REPORT Is Department of Justice Dismissal of Morgan Stanley Case a Litmus Test for Corruption Risk Compliance? November 1, 2012 In April 2012, a former Morgan Stanley managing director

More information

TCO Certified Self-assessment Questionnaire

TCO Certified Self-assessment Questionnaire ! TCO Certified Self-assessment Questionnaire A.7.2 Senior Management Representative, Socially Responsible Manufacturing Introduction: Completion of this Self-assessment Questionnaire is required under

More information

Customer Data and Reputational Risk in the Pharmaceutical Industry

Customer Data and Reputational Risk in the Pharmaceutical Industry 1 Customer Data and Reputational Risk in the Pharmaceutical Industry Sensitive Data: A Chain of Trust Organizations of all types, from banks to government agencies to healthcare providers, are taking steps

More information

Schedule 46 SAO Certificate FAQs

Schedule 46 SAO Certificate FAQs Schedule 46 SAO Certificate FAQs Ensuring Correct Completion and Submission of the SAO Certificate The first submission of the Schedule 46 Finance Act 2009 (FA09) senior accounting officer (SAO) certificate

More information

FORCED LABOUR WHY IT IS AN ISSUE FOR EMPLOYERS

FORCED LABOUR WHY IT IS AN ISSUE FOR EMPLOYERS FORCED LABOUR WHY IT IS AN ISSUE FOR EMPLOYERS INTERNATIONAL ORGANISATION OF EMPLOYERS SEPTEMBER 2010 INTRODUCTION Although forced labour is universally condemned and banned and many believe that it is

More information

GOVERNMENT CONTRACT. Westlaw Journal

GOVERNMENT CONTRACT. Westlaw Journal Westlaw Journal GOVERNMENT CONTRACT Litigation News and Analysis Legislation Regulation Expert Commentary VOLUME 26, ISSUE 13 / OCTOBER 29, 2012 Expert Analysis Switching to Offense in Government Contracting:

More information

Directors Duties. Directors Duties

Directors Duties. Directors Duties Directors Duties The Companies Act 2014 (the Act ), for the first time, codifies directors duties, drawing together both existing statutory rules on transactions involving directors and also the various

More information

Construction Industry Workers Compensation Coverage Act. Approved by the NCOIL Executive Committee on November 22, 2009.

Construction Industry Workers Compensation Coverage Act. Approved by the NCOIL Executive Committee on November 22, 2009. Construction Industry Workers Compensation Coverage Act Approved by the NCOIL Executive Committee on November 22, 2009. Table of Contents Page Numbers Section 1. Summary (1) Section 2. Definitions (1)

More information

KNOW YOUR THIRD PARTY

KNOW YOUR THIRD PARTY Thomson Reuters KNOW YOUR THIRD PARTY EXECUTIVE SUMMARY The drive to improve profitability and streamline operations motivates many organizations to collaborate with other businesses, increase outsourcing

More information

Texas Security Freeze Law

Texas Security Freeze Law Texas Security Freeze Law BUSINESS & COMMERCE CODE CHAPTER 20. REGULATION OF CONSUMER CREDIT REPORTING AGENCIES 20.01. DEFINITIONS. In this chapter: (1) "Adverse action" includes: (A) the denial of, increase

More information

FINANCIAL SERVICES FLASH REPORT

FINANCIAL SERVICES FLASH REPORT FINANCIAL SERVICES FLASH REPORT The Volcker Rule: The End of Proprietary Trading? October 13, 2011 This week in the United States, the Federal Reserve Board, the Office of the Comptroller of the Currency,

More information

Control Self-Assessment. The Future of Store Audits in Retail Stores

Control Self-Assessment. The Future of Store Audits in Retail Stores Control Self-Assessment The Future of Store Audits in Retail Stores Introduction According to the 2003 National Retail Security Survey, produced by Richard Hollinger at the University of Florida, retailers

More information

CODE OF ETHICS AND BUSINESS CONDUCT

CODE OF ETHICS AND BUSINESS CONDUCT CODE OF ETHICS AND BUSINESS CONDUCT Date of Issue: 22 January 2015 Version number: 2 LUXFER HOLDINGS PLC Code of Ethics and Business Conduct Luxfer Holdings PLC is committed to conducting its business

More information

NEW YORK CITY FALSE CLAIMS ACT Administrative Code 7-801 through 7-810 *

NEW YORK CITY FALSE CLAIMS ACT Administrative Code 7-801 through 7-810 * NEW YORK CITY FALSE CLAIMS ACT Administrative Code 7-801 through 7-810 * 7-801. Short title. This chapter shall be known as the "New York city false claims act." 7-802. Definitions. For purposes of this

More information

Simplify the Complexity of Managing 3rd Party Anti-Bribery / FCPA Compliance

Simplify the Complexity of Managing 3rd Party Anti-Bribery / FCPA Compliance Simplify the Complexity of Managing 3rd Party Anti-Bribery / FCPA Compliance Arm Stakeholders with Critical Information to Assess 3rd Party Relationships and Comply with the Foreign Corrupt Practices Act

More information

Managing Regulatory Compliance and AML Risk in a Virtual Currency World

Managing Regulatory Compliance and AML Risk in a Virtual Currency World Managing Regulatory Compliance and AML Risk in a Virtual Currency World Issue When you first think of virtual currency (also known as digital currency), the video gaming industry may be what first comes

More information

Compliance Requirements for Healthcare Carriers

Compliance Requirements for Healthcare Carriers INFORMATION DRIVES SOUND ANALYSIS, INSIGHT REGULATORY COMPLIANCE ADVISORY Compliance Requirements for Healthcare Carriers Introduction With the introduction of the new healthcare exchanges in January 2014

More information

BUSINESS PRINCIPLES FOR COUNTERING BRIBERY A MULTI-STAKEHOLDER INITIATIVE LED BY TRANSPARENCY INTERNATIONAL

BUSINESS PRINCIPLES FOR COUNTERING BRIBERY A MULTI-STAKEHOLDER INITIATIVE LED BY TRANSPARENCY INTERNATIONAL BUSINESS PRINCIPLES FOR COUNTERING BRIBERY A MULTI-STAKEHOLDER INITIATIVE LED BY TRANSPARENCY INTERNATIONAL Transparency International is the global civil society organisation leading the fight against

More information

PROTIVITI FLASH REPORT

PROTIVITI FLASH REPORT PROTIVITI FLASH REPORT Cybersecurity Framework: Where Do We Go From Here? February 25, 2014 Just over a year ago, President Barack Obama signed an Executive Order (EO) calling for increased cybersecurity

More information

Fraud Prevention and Detection in a Manufacturing Environment

Fraud Prevention and Detection in a Manufacturing Environment Fraud Prevention and Detection in a Manufacturing Environment Introduction The Association of Certified Fraud Examiners (ACFE) estimated in its 2008 Report to the Nation on Occupational Fraud and Abuse

More information

Accountability Report Card Summary 2013 Massachusetts

Accountability Report Card Summary 2013 Massachusetts Accountability Report Card Summary 2013 Massachusetts Massachusetts has a relatively good state whistleblower law: Scoring 64 out of a possible 100 points; and Ranking 11 th out of 51 (50 states and the

More information

Guidance ETHICAL PROCUREMENT AND SUPPLY

Guidance ETHICAL PROCUREMENT AND SUPPLY ETHICAL PROCUREMENT AND SUPPLY Published by the British Institute of Facilities Management June 2015 Introduction The importance of ethical procurement and supply The majority of organisations use supply

More information

Statement on G7 Topic Trade and Supply Chain Standards

Statement on G7 Topic Trade and Supply Chain Standards Statement on G7 Topic Trade and Supply Chain Standards Together, the G7 states produce 32 per cent of the global gross domestic product. A large number of companies located in the G7 countries are active

More information

PROTIVITI FLASH REPORT

PROTIVITI FLASH REPORT PROTIVITI FLASH REPORT New Internal Control Requirements for Companies with Operations in India November 9, 2015 In the aftermath of major global financial frauds, several countries enacted legislation

More information

FINANCIAL SERVICES FLASH REPORT

FINANCIAL SERVICES FLASH REPORT FINANCIAL SERVICES FLASH REPORT The Fourth European Union Anti-Money Laundering Directive July 2015 The Fourth European Union (EU) Anti-Money Laundering Directive (Fourth Directive) was approved by the

More information

Certification Required by the California Transparency in Supply Chains Act of 2010

Certification Required by the California Transparency in Supply Chains Act of 2010 Certification Required by the California Transparency in Supply Chains Act of 2010 1. Flextronics Pledge Overview 1 Flextronics Pledge s four cornerstones People, Environment, Ethics and Governance, and

More information

COLORADO CREDIT SERVICES ORGANIZATION ACT. Table of Contents COLORADO CREDIT SERVICES ORGANIZATION ACT... 1

COLORADO CREDIT SERVICES ORGANIZATION ACT. Table of Contents COLORADO CREDIT SERVICES ORGANIZATION ACT... 1 COLORADO CREDIT SERVICES ORGANIZATION ACT Table of Contents COLORADO CREDIT SERVICES ORGANIZATION ACT... 1 12-14.5-101. Short title.... 1 12-14.5-102. Legislative declaration.... 1 12-14.5-103. Definitions...

More information

{>> Foreign Corrupt Practices Act //]

{>> Foreign Corrupt Practices Act //] {>> Foreign Corrupt Practices Act //] FCPA Defintion FCPA Definition FOREIGN CORRUPT PRACTICES ACT - The risk of doing business abroad has just increased dramatically as non compliance with the Foreign

More information

FINANCIAL SERVICES FLASH REPORT

FINANCIAL SERVICES FLASH REPORT FINANCIAL SERVICES FLASH REPORT OCC Finalizes Its Heightened Standards for Large Financial Institutions September 15, 2014 Transforming Heightened Expectations to Minimum Standards On September 2, 2014,

More information

Code. of Conduct for Suppliers

Code. of Conduct for Suppliers Code of Conduct for Suppliers Code of Conduct for Odebrecht Oil & Gas Suppliers 1 INTRODUCTION The operation in domestic and foreign markets and in different business units, geographical regions and cultural

More information

CODE OF CONDUCT as adopted by the Board of Directors on 20 February 2015

CODE OF CONDUCT as adopted by the Board of Directors on 20 February 2015 GOLDFIELDS MONEY LIMITED ACN 087 651 849 CODE OF CONDUCT as adopted by the Board of Directors on 20 February 2015 1. Purpose This Code of Conduct (Code) clearly states the standards of responsibility and

More information

CREDIT REPAIR SERVICES (California Civil Code 1789.10 et seq.; 15 U.S.C.A. 1679 et seq.)

CREDIT REPAIR SERVICES (California Civil Code 1789.10 et seq.; 15 U.S.C.A. 1679 et seq.) Legal Affairs 1625 North Market Blvd., Suite S 309, Sacramento, CA 95834 www.dca.ca.gov Legal Guide CR-9 CREDIT REPAIR SERVICES (California Civil Code 1789.10 et seq.; 15 U.S.C.A. 1679 et seq.) January

More information

Forget Chicken Little The Sky is Falling: Current Enterprise Risk Management Strategies for Product Recalls and Corporate Compliance Matters

Forget Chicken Little The Sky is Falling: Current Enterprise Risk Management Strategies for Product Recalls and Corporate Compliance Matters Forget Chicken Little The Sky is Falling: Current Enterprise Risk Management Strategies for Product Recalls and Corporate Compliance Matters Mark Kaster Dorsey & Whitney LLP Carol Peterson 3M Company Peter

More information

company policy number 0001 LEGAL AND ETHICAL CONDUCT

company policy number 0001 LEGAL AND ETHICAL CONDUCT company policy number 0001 LEGAL AND ETHICAL CONDUCT eff. date replaces page 28 Mar. 2011 14 Feb. 2006 1 of 10 PURPOSE CPI has adopted this Code of Legal and Ethical Conduct ( Code ) to promote: honest

More information

POLICY ON INSIDE INFORMATION AND INSIDER TRADING

POLICY ON INSIDE INFORMATION AND INSIDER TRADING FTI CONSULTING, INC. POLICY ON INSIDE INFORMATION AND INSIDER TRADING I. Overview FTI Consulting, Inc., together with its subsidiaries and affiliates ( FTI Consulting or the Company ), are committed to

More information

Code of Conduct Sourcing & Supply Chain FAU-F-SPG-2400/EN

Code of Conduct Sourcing & Supply Chain FAU-F-SPG-2400/EN Code of Conduct Sourcing & Supply Chain FAU-F-SPG-2400/EN Background Faurecia, a global automotive supplier, is committed to growth founded on socially-responsible actions and behaviors in all countries

More information

C O N F I D E N T I A L A N D P R O P R I E T A R Y. Page 1 of 7 Title: FRAUD, WASTE, AND ABUSE POLICY

C O N F I D E N T I A L A N D P R O P R I E T A R Y. Page 1 of 7 Title: FRAUD, WASTE, AND ABUSE POLICY Page 1 of 7 1. Purpose As a Company that does business with U.S. state and federal government health care programs (such as Medicare and Medicaid), Hill-Rom is required to maintain a system of policies

More information

NOTICE TO CLIENTS WHO CONTEMPLATE FILING BANKRUPTCY

NOTICE TO CLIENTS WHO CONTEMPLATE FILING BANKRUPTCY NOTICE TO CLIENTS WHO CONTEMPLATE FILING BANKRUPTCY The purpose of this Notice and The Statement Mandated by Section 527(b) of the Bankruptcy Code, which you have been provided as a separate document are

More information

Consumer Affairs Laws Section 1380 and Regulations

Consumer Affairs Laws Section 1380 and Regulations Insurance Consumer Protection The Gramm-Leach-Bliley Financial Services Modernization Act (the Act) was enacted on November 12, 1999. Section 305 of the Act required the federal banking agencies (the Agencies)

More information

COLLINS FOODS LIMITED (the COMPANY) CODE OF CONDUCT

COLLINS FOODS LIMITED (the COMPANY) CODE OF CONDUCT COLLINS FOODS LIMITED (the COMPANY) CODE OF CONDUCT 1. Introduction The Company is committed to maintaining ethical standards in the conduct of its business activities. The Company's reputation as an ethical

More information

CFPB Compliance Bulletin 2015-05. Date: October 8, 2015 Subject: RESPA Compliance and Marketing Services Agreements

CFPB Compliance Bulletin 2015-05. Date: October 8, 2015 Subject: RESPA Compliance and Marketing Services Agreements Consumer Financial Protection Bureau 1700 G Street NW, Washington, DC 20552 CFPB Compliance Bulletin 2015-05 Date: October 8, 2015 Subject: RESPA Compliance and Marketing Services Agreements The Consumer

More information

General Contract Clauses: Corporate Social Responsibility Representations and Warranties

General Contract Clauses: Corporate Social Responsibility Representations and Warranties General Contract Clauses: Corporate Social Responsibility Representations and Warranties Mark S. Ostrau and Ashley C. Walter, Fenwick & West LLP, with PLC Commercial These Standard Clauses provide general

More information

ANTI-BRIBERY AND FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY

ANTI-BRIBERY AND FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY Issued: November 12, 2013 ANTI-BRIBERY AND FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY SCOPE This policy applies to all Magnetek, Inc. ( Magnetek ) employees, its subsidiaries and affiliates worldwide,

More information

Mental Health Resources, Inc. Mental Health Resources, Inc. Corporate Compliance Plan Corporate Compliance Plan

Mental Health Resources, Inc. Mental Health Resources, Inc. Corporate Compliance Plan Corporate Compliance Plan Mental Health Resources, Inc. Mental Health Resources, Inc. Corporate Compliance Plan Corporate Compliance Plan Adopted: January 2, 2007 Revised by Board of Directors on September 4, 2007 Revised and Amended

More information

The Critical Role of the Board of Directors in Acquisitions

The Critical Role of the Board of Directors in Acquisitions The Critical Role of the Board of Directors in Acquisitions Note: This paper originally was published in October 2013 by Transaction Advisors (www.transactionadvisors.com). Many are predicting the M&A

More information

Executive Order 13627 Strengthening Protections Against Trafficking in Persons in Federal Contracts September 25, 2012

Executive Order 13627 Strengthening Protections Against Trafficking in Persons in Federal Contracts September 25, 2012 Administration of Barack Obama, 2012 Executive Order 13627 Strengthening Protections Against Trafficking in Persons in Federal Contracts September 25, 2012 By the authority vested in me as President by

More information

Worldwide Anti-Corruption Policy

Worldwide Anti-Corruption Policy Worldwide Anti-Corruption Policy I. PURPOSE The laws of most countries make the payment or offer of payment or even receipt of a bribe, kickback or other corrupt payment a crime, subjecting both Eaton

More information

what your business needs to do about the new HIPAA rules

what your business needs to do about the new HIPAA rules what your business needs to do about the new HIPAA rules Whether you are an employer that provides health insurance for your employees, a business in the growing health care industry, or a hospital or

More information

HIPAA Privacy and Security Changes in the American Recovery and Reinvestment Act

HIPAA Privacy and Security Changes in the American Recovery and Reinvestment Act International Life Sciences Arbitration Health Industry Alert If you have questions or would like additional information on the material covered in this Alert, please contact the author: Brad M. Rostolsky

More information

Aegon sustainable procurement policy

Aegon sustainable procurement policy Aegon sustainable procurement policy aegon.com The Hague, April 2013 Introduction Aegon N.V., through its operating subsidiaries, is a leading provider of life insurance, pensions and asset management.

More information

Contract and Vendor Management Guide

Contract and Vendor Management Guide Contents 1. Guidelines for managing contracts and vendors... 2 1.1. Purpose and scope... 2 1.2. Introduction... 2 2. Contract and Vendor Management 2.1. Levels of management/segmentation... 3 2.2. Supplier

More information

Cloud Security Keeping Data Safe in the Boundaryless World of Cloud Computing

Cloud Security Keeping Data Safe in the Boundaryless World of Cloud Computing Cloud Security Keeping Data Safe in the Boundaryless World of Cloud Computing Executive Summary As cloud service providers mature, and expand and refine their offerings, it is increasingly difficult for

More information

MEDICAID COMPLIANCE POLICY

MEDICAID COMPLIANCE POLICY 6232 MEDICAID COMPLIANCE POLICY It is the policy of the Board of Education that all school district s practices regarding Medicaid claims for services be in compliance with all applicable federal and state

More information

SEC FLASH REPORT. SEC Issues Rules for Implementing the Whistleblower Provisions of Section 21F of the Securities Exchange Act of 1934

SEC FLASH REPORT. SEC Issues Rules for Implementing the Whistleblower Provisions of Section 21F of the Securities Exchange Act of 1934 SEC FLASH REPORT SEC Issues Rules for Implementing the Whistleblower Provisions of Section 21F of the Securities Exchange Act of 1934 May 25, 2011 Today, the Securities and Exchange Commission (SEC) voted

More information

Payment Card Industry Data Security Standards

Payment Card Industry Data Security Standards Payment Card Industry Data Security Standards Discussion Objectives Agenda Introduction PCI Overview and History The Protiviti Difference Questions and Discussion 2 2014 Protiviti Inc. CONFIDENTIAL: This

More information

Daily Environment Report

Daily Environment Report Daily Environment Report Reproduced with permission from Daily Environment Report, 245 DEN B-1, 12/22/2014. Copyright 2014 by The Bureau of National Affairs, Inc. (800-372-1033) http://www.bna.com Environmental

More information

CHARTER DOCUMENT FAIR LABOR ASSOCIATION

CHARTER DOCUMENT FAIR LABOR ASSOCIATION As Amended, February 20, 2013 CHARTER DOCUMENT FAIR LABOR ASSOCIATION TABLE OF CONTENTS Pages I. DEFINITIONS...4 II. GOVERNANCE OF THE ASSOCIATION...7 A. Structure...7 B. Board of Directors of the Association...8

More information

Fifth annual survey. Look before you leap Navigating risks in emerging markets

Fifth annual survey. Look before you leap Navigating risks in emerging markets Fifth annual survey Look before you leap Navigating risks in emerging markets Table of contents 1 Executive summary 3 Significant concerns over compliance and integrity-related risks 4 Bribery leads the

More information

TITLE 34. LABOR AND WORKERS' COMPENSATION CHAPTER 19. CONSCIENTIOUS EMPLOYEE PROTECTION ACT. N.J. Stat. 34:19-1 (2007)

TITLE 34. LABOR AND WORKERS' COMPENSATION CHAPTER 19. CONSCIENTIOUS EMPLOYEE PROTECTION ACT. N.J. Stat. 34:19-1 (2007) TITLE 34. LABOR AND WORKERS' COMPENSATION CHAPTER 19. CONSCIENTIOUS EMPLOYEE PROTECTION ACT N.J. Stat. 34:19-1 (2007) 34:19-1. Short title This act shall be known and may [be] cited as the "Conscientious

More information

Accountability Report Card Summary 2013 New Mexico

Accountability Report Card Summary 2013 New Mexico Accountability Report Card Summary 2013 New Mexico New Mexico has a pretty strong state whistleblower law: Scoring 72 out of a possible 100 points; Ranking 4 th out of 51 (50 states and the District of

More information

Please contact me on 0207 213 4378 or geoff.lane@uk.pwc.com if you would like to discuss this further.

Please contact me on 0207 213 4378 or geoff.lane@uk.pwc.com if you would like to discuss this further. House of Commons Public Bill Committee, Scrutiny Unit, 7 Millbank, London, SW1P 3JA. 8 September 2014 Dear Sirs, Modern Slavery Bill call for written evidence We appreciate the opportunity to respond to

More information

WESTERN ASSET MORTGAGE CAPITAL CORPORATION CODE OF CONDUCT

WESTERN ASSET MORTGAGE CAPITAL CORPORATION CODE OF CONDUCT WESTERN ASSET MORTGAGE CAPITAL CORPORATION CODE OF CONDUCT I. Introduction This Code of Conduct (the "Code") sets out basic principles to guide the day-today business activities of directors, officers

More information

Policy-Standard heading. Fraud and Corruption Policy

Policy-Standard heading. Fraud and Corruption Policy Policy-Standard heading Fraud and Corruption Policy September 2013 Table of contents Introduction 3 Purpose 3 Scope 3 Related Policies and Processes 3 Definition of Fraud and Corruption 4 Policy 4 Code

More information

The Long Arm of the U.S. Foreign Corrupt Practices Act: Complying with the FCPA in the Vietnamese Landscape

The Long Arm of the U.S. Foreign Corrupt Practices Act: Complying with the FCPA in the Vietnamese Landscape The Long Arm of the U.S. Foreign Corrupt Practices Act: Complying with the FCPA in the Vietnamese Landscape Foreign Corrupt Practices Act: The Act What is the Act? Anti-Bribery Provisions Book and Record

More information

Alliance to End Slavery and Trafficking 1700 Pennsylvania Avenue, NW Suite 520 Washington, DC 20006 www.endslaveryandtrafficking.

Alliance to End Slavery and Trafficking 1700 Pennsylvania Avenue, NW Suite 520 Washington, DC 20006 www.endslaveryandtrafficking. Alliance to End Slavery and Trafficking 1700 Pennsylvania Avenue, NW Suite 520 Washington, DC 20006 www.endslaveryandtrafficking.org Written Comments to Department of Defense (DoD), General Services Administration

More information

PHOENIX NEW MEDIA LIMITED FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY

PHOENIX NEW MEDIA LIMITED FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY PHOENIX NEW MEDIA LIMITED FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY Phoenix New Media Limited (together with its subsidiaries, the Company ) is committed to conducting all aspects of its business

More information

Standards of. Conduct. Important Phone Number for Reporting Violations

Standards of. Conduct. Important Phone Number for Reporting Violations Standards of Conduct It is the policy of Security Health Plan that all its business be conducted honestly, ethically, and with integrity. Security Health Plan s relationships with members, hospitals, clinics,

More information

Introduction to Social Compliance & Its Business Benefits

Introduction to Social Compliance & Its Business Benefits Proposal for Conducting Seminar on Introduction to Social Compliance & Its Business Benefits Submitted to: Environment Agency, Abu Dhabi Table of Contents Summary..02 Seminar Objectives 02 Content Outline..02

More information

PHOENIX NEW MEDIA LIMITED STATEMENT OF POLICIES GOVERNING MATERIAL, NON-PUBLIC INFORMATION AND THE PREVENTION OF INSIDER TRADING

PHOENIX NEW MEDIA LIMITED STATEMENT OF POLICIES GOVERNING MATERIAL, NON-PUBLIC INFORMATION AND THE PREVENTION OF INSIDER TRADING PHOENIX NEW MEDIA LIMITED STATEMENT OF POLICIES GOVERNING MATERIAL, NON-PUBLIC INFORMATION AND THE PREVENTION OF INSIDER TRADING Adopted on [ ], 2011 and effective conditional and immediately upon commencement

More information

Promoting responsible electronics supply chains through public procurement

Promoting responsible electronics supply chains through public procurement Business, Human Rights and the Environment Research Group Promoting responsible electronics supply chains through public procurement Olga Martin-Ortega, Opi Outhwaite and William Rook The School of Law,

More information

NASSAU COUNTY INDUSTRIAL DEVELOPMENT AGENCY WHISTLEBLOWER POLICY

NASSAU COUNTY INDUSTRIAL DEVELOPMENT AGENCY WHISTLEBLOWER POLICY NASSAU COUNTY INDUSTRIAL DEVELOPMENT AGENCY WHISTLEBLOWER POLICY This Policy is adopted pursuant to the provisions of the Public Authorities Accountability Act of 2005 and the Public Authorities Reform

More information

Chapter Five: Respect for Human Rights in Joint Ventures Relationships

Chapter Five: Respect for Human Rights in Joint Ventures Relationships 73 Chapter Five: Respect for Human Rights in Joint Ventures Relationships Overview Brief overview of joint ventures relationships Joint ventures (JVs) are formed when companies combine their resources

More information

LANTHEUS HOLDINGS, INC. Foreign Corrupt Practices Act and Anti-Bribery Compliance Policy

LANTHEUS HOLDINGS, INC. Foreign Corrupt Practices Act and Anti-Bribery Compliance Policy LANTHEUS HOLDINGS, INC. Foreign Corrupt Practices Act and Anti-Bribery Compliance Policy 1. Introduction. Applicability. This Foreign Corrupt Practices Act and Anti-Bribery Compliance Policy (this Policy

More information

M E M O R A N D U M. The Policy provides for blackout periods during which you are prohibited from buying or selling Company securities.

M E M O R A N D U M. The Policy provides for blackout periods during which you are prohibited from buying or selling Company securities. M E M O R A N D U M TO: FROM: All Directors, Officers and Covered Persons of Power Solutions International, Inc. and its Subsidiaries Catherine Andrews General Counsel and Insider Trading Compliance Officer

More information

OIG Open Letter Regarding the Self-Disclosure Protocol: Further Refinements

OIG Open Letter Regarding the Self-Disclosure Protocol: Further Refinements 2009 American Health Lawyers Association April 17, 2009 Vol. VII Issue 15 OIG Open Letter Regarding the Self-Disclosure Protocol: Further Refinements By Ritu Kaur Singh, Frank E. Sheeder III, and Gerald

More information

FIDUCIARY AND INVESTMENT RESPONSIBILITIES

FIDUCIARY AND INVESTMENT RESPONSIBILITIES FIDUCIARY AND INVESTMENT RESPONSIBILITIES Purpose (See R. S. 11:261) The legislature recognizes that the fiscal integrity of various governments of and within this state and the financial security of employees

More information

Preventing Fraud: Assessing the Fraud Risk Management Capabilities of Today s Largest Organizations

Preventing Fraud: Assessing the Fraud Risk Management Capabilities of Today s Largest Organizations Preventing Fraud: Assessing the Fraud Risk Management Capabilities of Today s Largest Organizations Overview In late 2006 and 2007, Protiviti commissioned a study to gauge the fraud risk management (FRM)

More information

Information for Business Partners

Information for Business Partners Information for Business Partners Compliance with laws, regulations and conventions Transparent in business www.siemens.com/compliance The culture of a company and its values make the difference. People

More information

Federation of Law Societies of Canada. Ottawa, November 26, 2013

Federation of Law Societies of Canada. Ottawa, November 26, 2013 Submission to the Standing Senate Committee on Banking, Trade and Commerce in Respect of Bill C-4 (a second Act to implement certain provisions of the budget tabled in Parliament on March 21, 2013 and

More information

Frequently Asked Questions Regarding the Sarbanes-Oxley Act Executive Certification Requirements

Frequently Asked Questions Regarding the Sarbanes-Oxley Act Executive Certification Requirements Frequently Asked Questions Regarding the Sarbanes-Oxley Act Executive Certification Requirements Table of Contents Page No. Introduction 3 Applicability of Requirements 1. Which companies are subject to

More information

ILLINOIS CREDIT REPAIR LAWS

ILLINOIS CREDIT REPAIR LAWS ILLINOIS CREDIT REPAIR LAWS This page contains information about starting a credit repair business in Illinois as well as legal information and Credit Repair laws for the State of Illinois. IL ST Ch. 815,

More information

European Code for Export Compliance

European Code for Export Compliance European Code for Export Compliance EU-CEC European Institute For Export Compliance EU-ECF EU Export Compliance Framework: EU Export Compliance Charter The European Code for Export Compliance EU-CEC 1.

More information

U.S. SQUASH Whistleblower Policy

U.S. SQUASH Whistleblower Policy General The United States Squash Racquets Association, Inc. d/b/a U.S. SQUASH ( U.S. SQUASH ) Ethics, Principles and Conflict of Interest Policy ( Ethics Policy ) requires directors, officers and employees

More information

The Coalition to Abolish Slavery & Trafficking

The Coalition to Abolish Slavery & Trafficking The Coalition to Abolish Slavery & Trafficking Modern Day Slavery and the CA Transparency in Supply Chains Act Presenter: Vanessa Lanza, Director of Partnerships, Human Trafficking in an Era of Globalization

More information

Administrative Policy No. AD 2.26 Title:

Administrative Policy No. AD 2.26 Title: I. SCOPE: Administrative Policy No. AD 2.26 Page: 1 of 5 This policy applies to all directors, officers, employees, agents, and shareholders of Tenet Healthcare Corporation, its subsidiaries and/or affiliates

More information

complying with the executive order against trafficking in federal Contracts Of the 20.9 million

complying with the executive order against trafficking in federal Contracts Of the 20.9 million 40 Contract Management March 2014 Contract Management March 2014 41 Of the 20.9 million people conservatively estimated by the International Labour Organization to be in forced labor around the world at

More information

Key Definitions: VT LEG #309032 v.1

Key Definitions: VT LEG #309032 v.1 Key Definitions: Side-by-Side Comparison of Vermont s Law and New Jersey s CEPA Prepared on May 6, 2015 by Damien Leonard, Esq. Office of Legislative Council Defines employer to include both public and

More information

Conflict Minerals Policy CONFLICTMINERALS CONFLICTMINERALS CONFLICTMINERALS CONFLICTMINERALS.

Conflict Minerals Policy CONFLICTMINERALS CONFLICTMINERALS CONFLICTMINERALS CONFLICTMINERALS. Conflict Minerals Policy www.ttigroup.com Contents 1. Overview 4 1.1 Introduction 4 1.2 Objective(s) 4 1.3 Applicability 4 2. Policy Requirements 5 2.1 Expectations 5 2.2 Requirements 5 2.3 Onboarding

More information

Internal Auditing is an Asset for Small Companies as well as Large Ones

Internal Auditing is an Asset for Small Companies as well as Large Ones Internal Auditing is an Asset for Small Companies as well as Large Ones The term internal audit usually inspires two immediate responses. The first is fear: Is something wrong in our organization? Have

More information

A SELECTICA GUIDE ALL THINGS STARK LAW WHAT IS STARK LAW, AND HOW CAN CONTRACT MANAGEMENT SOFTWARE HELP YOU COMPLY?

A SELECTICA GUIDE ALL THINGS STARK LAW WHAT IS STARK LAW, AND HOW CAN CONTRACT MANAGEMENT SOFTWARE HELP YOU COMPLY? A SELECTICA GUIDE ALL THINGS STARK LAW WHAT IS STARK LAW, AND HOW CAN CONTRACT MANAGEMENT SOFTWARE HELP YOU COMPLY? 1 A Selectica Guide All things Stark: What is Stark Law, and how can contract management

More information

STATEMENT FROM THE CHAIRMAN

STATEMENT FROM THE CHAIRMAN STATEMENT FROM THE CHAIRMAN In an ever-changing global marketplace, it is important for all of us to have an understanding of the responsibilities each of have in carrying out day-to-day business decisions

More information