PROTIVITI FLASH REPORT

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1 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 bribery and corruption risk in the retail industry have sent a strong signal that bribery and corruption risk can affect global companies in all industries, including retailing and consumer products manufacturers with retail outlets. As more of these global companies expand their retail operations into markets where consumer demand is growing, it is important they understand the requirements of the Foreign Corrupt Practices Act of 1977 (FCPA) in the United States and similar laws in other countries in which they do business. These recent reports warrant taking a look at corruption risk from a retail industry perspective. FCPA Prosecutions Are on the Upswing Corruption can cost companies, and their shareholders, a lot of money. Under the FCPA antibribery provisions: Corporations and other business entities are subject to a fine of up to $2,000,000, and officers, directors, shareholders, employees and agents are subject to a fine of up to $100,000 and imprisonment for up to five years. There are also other potential penalties, e.g., the threat of disgorgement of profits from the business obtained through illicit payments and suspension of the firm s right to do business with the U.S. government. Criminal enforcement under the FCPA has increased from just two enforcement actions in 2004 to 48 in It is estimated there are at least 100 open investigations at the present time. Some believe that the U.S. Justice Department has gone too far in its interpretation and enforcement of the FCPA. For example, two years ago the U.S. Chamber Institute for Legal Reform proposed five amendments to the FCPA to ensure the law and its enforcement do not encumber U.S. competitiveness: 1 (1) Adopt a compliance defense permitting companies to fight the imposition of criminal liability for FCPA violations if they have made good-faith efforts to comply with the law. (2) Limit or eliminate successor criminal FCPA liability for an acquired company. (3) Add a willfulness requirement for corporate criminal liability. (4) Limit a parent company s civil liability for the acts of a subsidiary. (5) Clarify the definition of foreign official to remove the ambiguity around what it means. 1 Restoring Balance: Proposed Amendments to the Foreign Corrupt Practices Act, U.S. Chamber Institute for Legal Reform, October 2010.

2 Congressional hearings have been conducted over the last year to assess whether the FCPA should be updated for changes in business since the law was enacted nearly 35 years ago. The general themes of these hearings are whether (a) the FCPA is spawning unfair and unjust prosecutorial activity, and (b) there are any ambiguities in the law that are hamstringing business and/or hurting job creation, resulting in companies incurring excessive compliance costs because they would rather be safe than sorry. On the other hand, corporate governance advocates see proposals to change the FCPA as possibly undermining the act s effectiveness. While our focus in this Flash Report is on the FCPA, there are other anti-bribery laws that retailers and consumer products manufacturers with retail outlets should be concerned with. For example, in 2010 the U.K. Parliament passed the country s first major overhaul of its anticorruption laws in over a century, putting companies operating in the United Kingdom under the most stringent anti-corruption regulation in the world, going even further than the requirements set down by the FCPA. This so-called Bribery Act introduced a new offense that makes corporations operating in the United Kingdom automatically liable for bribes paid on their behalf. Corporations could now face criminal sanctions if management fails to demonstrate that adequate procedures designed to prevent bribery have been implemented and are taken seriously. How Retailers Can Get into Trouble The Warning Signs When retailers and consumer products companies expand their retailing activities to other markets, they may interact with customs officials and tax authorities, acquire licenses and permits, obtain work permits and visas, and be subject to inspections and certifications. For example, retailers and consumer products companies may require a global effort to identify, acquire and/or lease large amounts of real estate for retail space. They may face health, safety and environmental, and other regulatory issues requiring inspections by local agencies. They may even face local established competitors who are paying accommodations to derail the efforts of new entrants. Facilitation payments to move products across borders or through local customs also require attention, because they are not permissible under the U.K. Bribery Act. Finally, they may have to procure a license to conduct business. All of these activities present opportunities for influence payments in high-corruption countries. Accordingly, retailers face significant challenges in each local market, leading to a heightened sensitivity to corruption risk in markets in which such activities are customary. The point is that even routine business transactions overseas often give rise to opportunities for the occurrence of corruption risk involving foreign officials. For these reasons, global retailers and consumer products companies with retail outlets should periodically assess their exposure to corruption risk using seven broad categories of illustrative questions they should be asking about their international business activities: Country risk profile: What is the cultural, political and regulatory environment of the countries in which the retailer conducts business? Is the organization operating in countries with a history of bribery and corruption? For example, consider that Brazil, Russia, India and China (the so-called BRIC countries) each have high-growth potential. Consider further that in the next 10 years, the largest growth in consumer spending is expected to occur in Russia. Recognizing that retailers may expand into these countries where there is a high risk that payoffs are going to be significant, proactive compliance programs are a must for retailers expanding into such countries. How much control does the retailer have over its foreign operations? (Note: The more disconnected the retailer is from its foreign representatives, the higher its risk Protiviti 2

3 of violating anti-bribery laws. To this point, many consumer products companies with their own retail outlets use agents in foreign locations. Some of these companies are of the view that this organizational structure insulates them from FCPA exposure. However, they may not be as insulated as they think they are.) Extent of the due diligence performed on potential foreign business partners and representatives: Have you investigated whether any payments are, in fact, being made to public officials who are employees, officers, agents, etc.? Does a foreign joint venture partner or representative refuse to provide a written certification that it will not take any action in furtherance of an unlawful offer, promise or payment to a foreign public official and not undertake any act that would cause the U.S. firm to be in violation of the FCPA? Is there an apparent lack of qualifications or resources on the part of a joint venture partner or representative to perform the services offered? Is the joint venture partner or representative related to, or recommended by, an official of the potential governmental customer? Does the retailer provide awareness training for foreign partners, agents and other representatives? Nature of payments and expenditures in foreign countries: What gifts, meals and entertainment are provided to those with whom the retailer or consumer products company does business in overseas markets? What charitable donations or political contributions are made in-country by the organization and its representatives? What types of leasing agreements has the retailer or consumer products company arranged in foreign countries? Are there unusual payment patterns, unusually high commission structures or special financial arrangements involving the retailer/consumer products company or its foreign subsidiaries and related third parties? Business model and relationships: How is business transacted in foreign countries? (Note: Sourcing and buying foreign goods in the United States from a U.S. company that imported the goods into the United States is much lower in risk than, say, maintaining retailing outlets overseas. While the first scenario is not without risk, it is normally the least risky of alternative business models. Again, the greater the involvement with foreign governments or their instrumentalities, the higher the risk.) What is the nature of business relationships with public international organizations, state-owned business enterprises, foreign governments, foreign municipalities, foreign legislative bodies, foreign political parties and/or royal families? Does the retailer or consumer products company hire foreign officials and/or members of their families as employees or contractors? Protiviti 3

4 Control over cash accounts and books and records: How are the retailer s bank accounts, petty cash funds and inventory monitored in non-u.s. locations? What controls are in place with respect to these assets? Is there a lack of transparency in expenses or accounting records within the retailer s organization and its third-party intermediaries (e.g., joint venture partners, agents, consultants, distributors, etc.)? Legal, regulatory and contractual matters: What business licenses, permits, certifications and inspections are required of the retailer or consumer products company in order to conduct business in overseas locations? Who has been granted power of attorney for your organization in non-u.s. jurisdictions? What terms and conditions do you include in written contracts with related third parties? How does the retailer or consumer products company monitor contract compliance? Policy and procedural matters: What policies and programs are currently in place to support compliance with the FCPA and other anti-bribery laws? What training initiatives are currently in place to create and sustain awareness of everyone s responsibility to comply with the FCPA and other anti-bribery laws? What process has been established for employees or third-party intermediaries to obtain advice on questionable or sensitive matters involving foreign officials? While the above questions are not intended to provide a complete diagnostic, answers to them may raise red flags requiring immediate attention of the retailing or consumer products organization s executive management and board of directors. How Retailers Can Manage FCPA and Anti-Bribery Compliance No matter what efforts are under way to reform the FCPA or the extent of pressure to drive reform, the law is still the law. Until it is changed, like all organizations, retailers and consumer products companies with their own retail outlets need the proper oversight and governance. Firms that paid bribes to foreign officials have been subjected to criminal and civil enforcement actions that have resulted in large fines and their employees and officers going to jail. It is not a pretty picture. To avoid such consequences, many firms have implemented detailed compliance programs intended to prevent, deter and detect improper payments by employees and agents. A robust FCPA and anti-bribery compliance program and corresponding controls typically include: Board oversight: Proactive understanding of potential corruption risks and oversight of anti-bribery or FCPA compliance program by the board. Executive management supervision: Coordination and management of the FCPA and anti-bribery compliance program by a designated senior executive. Policies, standards, procedures and reporting mechanisms: Documented antibribery, anti-corruption or FCPA policies and standards, along with communication of same to employees and those who conduct business on behalf of the company. Suitable Protiviti 4

5 policies to define the organization s stance on gifts and hospitality, facilitation payments, offset arrangements, payments to outside advisers/agents, and political contributions. An affirmation procedure requiring that critical employees, vendors and contractors provide written statements that they are in compliance with the requirements of the FCPA and other anti-bribery laws. Effective mechanisms for individuals to report criminal conduct, concerns and other complaints involving potential legal and regulatory violations. Risk assessment and due diligence activities: Risk identification process that includes explicit consideration of the risk of commercial bribery and corruption involving foreign officials and employees or agents who operate out of the home country, especially at locations known for unethical business practices. Due diligence of employees, joint venture partners and third-party agents. Anti-bribery or anti-corruption compliance language and representations incorporated in all third-party contracts. Effective internal controls and monitoring: Internal controls for books and records, as well as proper accounting. Active monitoring of anti-corruption controls within financial and operational processes to identify and report potential red flags of illegal behavior. Periodic audits of the FCPA or anti-bribery compliance program policies, procedures and controls to assess their effectiveness at ensuring compliance at all levels and across the entire organization. Areas of noncompliance and recommended solutions to enhance the retailing or consumer products organization s anti-bribery or anti-corruption compliance activities reported to senior management and the board. Critical transactions, such as those related to consulting services, reviewed for propriety. Training and awareness programs: FCPA and anti-bribery awareness education and training out of the home country for employees, third-party agents and consultants conducting business on behalf of the organization to ensure that they are knowledgeable of the appropriate behavior and legal requirements. Investigatory and disciplinary mechanisms: Thorough and comprehensive investigation and remediation of reported potential violations involving bribery and corruption. When an investigation is completed, determine in consultation with outside counsel whether any violations have occurred, and if so, weigh costs and benefits of voluntary disclosure to the government. Disciplinary mechanisms that are consistently enforced for those who violate the company s compliance policy. Large multinational retailers or consumer products companies cannot monitor every transaction of every dollar amount by every employee. However, these organizations do have a duediligence obligation to 1) establish policies and procedures that provide reasonable assurance that the organization and its people are adhering to the compliance requirements, and 2) implement adequate systems with sufficient internal controls. This includes establishing a compliance program that meets the standards of the Federal Sentencing Guidelines. Summary Civil and criminal fines stemming from FCPA violations and noncompliance with other antibribery laws can be costly. Firms that paid bribes to foreign officials have been subjected to criminal and civil enforcement actions, resulting in large fines and suspension and debarment from federal procurement contracting, and their employees and officers have gone to jail. Damage to reputation by negative headlines can devastate the bottom line and impair shareholder value. Retailers and consumer products companies entering new markets to seek fresh sources of consumer demand should pay attention to the risks of bribery and corruption. To avoid the Protiviti 5

6 consequences of legal and regulatory violations, many firms have implemented detailed compliance programs intended to prevent and detect improper payments by employees and agents. It is critical for management to ensure that it has a robust FCPA and anti-bribery compliance program, including anti-corruption controls, in place. A robust program provides a critical road map for any organization conducting business in today s global economy. FCPA and anti-bribery compliance and other corresponding internal control capabilities should be considered as part of a holistic strategy to address all issues that could arise from intentional illegal acts within the organization. In this Flash Report, we have not attempted to cover everything related to compliance with the U.S. Foreign Corrupt Practices Act and other anti-bribery laws in the United Kingdom and other countries, nor have we attempted to address all of the nuances in complying with such laws and regulations that are relevant to the matters we have covered in this Flash Report. For these and other reasons, the information in this Flash Report is not intended to be legal analysis or advice, nor does it purport to address every issue that may impact companies or every possible government response or interpretation of these matters. Accordingly, organizations should seek the advice of legal counsel or other appropriate advisors on specific questions related to the U.S. Foreign Corrupt Practices Act and other anti-bribery laws in the United Kingdom and other countries as they relate to their unique circumstances. 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. About Our Retail Industry Practice Protiviti serves retail and consumer products companies around the world by helping them identify, measure and manage the risks inherent in their industry. Our experts have the skills, talent and experience to detect red flags, pitfalls and most importantly opportunities in retail. As retailers and consumer products manufacturers and their suppliers continue to address an uneven economy and changing regulatory landscape, they are assessing and, if necessary, modifying their strategies and business processes on an ongoing basis. Technology, distribution, go-to-market campaigns and approaches to retailer-supplier collaboration all may be affected as these organizations seek to streamline operations while pursuing growth initiatives that will help them sustain competitive advantage. Our professionals specialize in making risk management capabilities and infrastructure practical and value-adding for retailers and consumer products manufacturers with their own retail outlets. We help these organizations assess their capabilities, identify areas for improvement, and collaborate closely with their teams to implement solutions. Our consultants have extensive experience with many leading companies across all sectors of the retail industry. And they are well-versed in the relevant business and industry-specific issues that retail organizations confront in their day-to-day business. We provide solutions that address the root causes of these challenges not just the symptoms. Related services: Supply chain management Vendor review Store audits Internal controls assessment PCI compliance Loss prevention For additional information about the issues reviewed here or Protiviti s services, please contact: Rick Childs Chris Wright Pam Verick Managing Director Managing Director Director 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.

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