Beyond Compliance: Building a Robust Ethics and Compliance Program
|
|
- Lesley Ward
- 8 years ago
- Views:
Transcription
1 Beyond Compliance: Building a Robust Ethics and Compliance Program
2 Overview Risks are increasing and organizations are called to develop effective compliance risk mitigation programs Today, the explosion of social media, new mobile technologies and big data has brought about a new era of transparency, exposing illegal transactions and raising new ethical questions in the way business is conducted. While ethics and compliance executives have progressed immensely in developing sophisticated measures to prevent, detect and mitigate risks, the same also holds true for those who wish to gain unfair advantage and violate the law. Risks are increasing and organizations are called to develop effective compliance risk mitigation programs and internal safeguards to protect against internal and external threats of corruption and fraud. Companies need to work on building capabilities that allow them to evaluate their corruption risks and embed controls that address them responsibly. Prosecutions and fines under the US Foreign Corrupt Practices Act (FCPA) have increased dramatically over the last decade¹, as well as under the UK Bribery Act, which is more restrictive than the FCPA. On top of increasing regulatory fines and legal costs, ethics and compliance problems can entail significant reputational risks if the public begins to question a company's ethics. These risks can be costly for organizations as information and misinformation travel through social media in an unprecedented rate. Additionally, these costs can be amplified as companies navigate tough economic conditions and emerging unfamiliar markets. At a time when risks are increasing, building a robust ethics and compliance program that not only protects from internal and external threats, but also enhances the brand is a key differentiator. ¹Shearman and Sterling, FCPA Digest: Recent Trends and Patterns in the Enforcement of the Foreign Corrupt Practices Act (New York: Shearman and Sterling, July 2012)
3 New studies, surveys and empirical evidence reveal that stock prices are higher, costs are lower and employees are more satisfied with companies demonstrating reputable ethical business practices and good governance.
4 Building Capabilities Effective ethics and compliance program as cornerstone for operational excellence and good governance There is a need for renewed focus on ethics and compliance programs in light of regulators ramping up enforcement in many areas, bribery among others. Because of increased enforcement and the resulting hefty fines as cost of noncompliance, organizations have redirected their efforts to ensuring effective anti-corruption compliance programs. At 360factors, we have dedicated an entire practice to assist our clients in this manner. Following are the steps to building a robust ethics and compliance program. Corporate Culture. An effective ethics and compliance program begins with the people and how they behave. The entire organization itself must be one in their underlying values, beliefs, attitudes and expectations towards unethical practices and corruption, and this culture is derived from the tone at the top. The board and senior management should set the tone and ensure that it permeates throughout the entire organization by espousing accountability. The board and senior management through actions should empower personnel to mitigate risks and build organizational trust. Everyone should be held accountable in what can be described as zero tolerance for any unethical behavior regardless of magnitude. And in the same breath, any act of upholding company values should be met with positive reinforcement. Understanding Key Laws. Building an ethics and compliance program requires a thorough understanding of key laws that govern companies with regard to corruption and unethical practices. The FCPA and UK Bribery Act are the most expansive in terms of prohibitions are jurisdictional reach, with the FCPA as the most aggressively enforced by several orders of magnitude. These are the laws that most global companies use as the standards for their ethics and compliance programs. Consult with your legal department about local bribery laws that might apply to the areas where you operate, but know and understand the FCPA and UK Bribery Act, and use them as the basis for your ethics and compliance program, including anticorruption policies, procedures, controls and training activities.
5 Foreign Corrupt Practices Act (FCPA) Defined² Enacted in 1977, the FCPA is a federal law that proscribes US persons and companies from paying bribes to foreign government officials for the purpose of obtaining or retaining business. The FCPA has two provisions that work in tandem: the anti-bribery provisions enforced by the Department of Justice and the accounting provisions enforced by the Securities and Exchange Commission. The accounting provisions require issuers to make and keep detailed books and records that accurately and fairly reflect the company s transactions and to have in place sound and adequate internal accounting controls. Risk Assessment. Essential to building an effective ethics and compliance program is risk identification and analysis. This entails a thorough assessment of risks posed by the company s nature of operations, the extent of business with governmental entities, agents and other intermediaries, its areas of operations and the regulatory environment. An assessment of the company s policies and controls for risk mitigation should also be conducted to either ensure effectiveness or identify gaps. Risk assessment lends efficiency and credibility to a company s ethics and compliance efforts should unforeseen issues arise as it demonstrates that the company is able to perform due diligence in assessing its risks. Design and Implementation. While the elements of ethics and compliance programs may vary per company, it should at least need to consist of the following: Operational guidelines on how compliance will be achieved in certain high-risk areas of operations Employee training and education Third-party monitoring Accurate financial recordkeeping Mechanism for reporting violations Ongoing monitoring of risks An effective ethics and compliance program should be a clear and unambiguous statement of the company s stand that bribery of any scale governmental or commercial will not be tolerated. ²See
6 UK Bribery Act Defined³ The UK Bribery Act details offences in relation to the four types of unethical activity: Bribing another person Accepting a bribe Bribing a foreign government official (non-uk) Failing to prevent a bribe The UK Bribery Act is one of the biggest changes in the areas of business and commerce. Unlike the FCPA, it introduces a new crime of failure to prevent bribery and companies must be able to demonstrate that they have implemented adequate procedure to prevent corrupt practices within the organization or by third parties on your behalf. Failure to do so could mean exposure to hefty fines as well as other collateral consequences, such as debarment from doing business with governments. Monitoring. Monitoring is a crucial element in an effective ethics and compliance program. Compliance programs that are not monitored are generally not very effective. Monitoring means anti-corruption compliance audits, data mining and analytics. It also means having the right people, processes and resources. As systems become more automated, companies are turning more and more to analytics or compliance management systems as a tool for monitoring. As with audits the key is to have the right tools in place as well as having the right personnel trained to analyze, interpret and spot anomalies. Anti-corruption audits send a powerful message that the board and senior management is committed to compliance and ensuring it is achieved. As risks change over time, comprehensive risk assessments should also be conducted periodically to make sure that the program is evolving and equipped to meet emerging risks. An extensive review of operational and enterprise risks should be done every few years or so to ensure the relevance of controls in place. ³See
7 How we can help 360factors Ethics and Compliance Risk Management Solutions 360factors uses cognitive technology and analytics to make ethics and compliance risk initiatives more effective and efficient through a simple yet comprehensive regulatory risk and compliance management model and methodology. Rise to regulatory challenges. Through our industry-focused approach, and using unique mapping and cognitive technology, we help companies manage their ethics and compliance programs based on FCPA and the UK Bribery Act regulations through a single platform. Drive high performance. Our experts use a unique risk, compliance and quality management platform that help capture real-time, relevant data to aid in the decision-making process to ultimately improve business outcomes. GRC automation. Our platform further allows companies to streamline GRC as a competitive differentiator, automating the entire risk process to protect them from a host of liabilities and enforcement action as well as streamlining the risk assessment process to manage operational and regulatory compliance. The best way to ensure anti-corruption compliance is with compliance software. Predict360 is a revolutionary regulatory risk and compliance management software that helps organizations stay in compliance. Organizations can document their operational controls and map them back to the corresponding requirements in Requirements Knowledge Base. When regulations are changed or updated, the organization is alerted on which policies and procedures need to be updated. It also provides the ability to manage risk and analyze the effects of operational controls on the risk index of the organization.
8 Learn how Predict360 can transform your compliance management process. Call today. Schedule a FREE TRIAL and DEMO online at Headquarters 1380 Burnet Road, Suite 100 Austin, Texas Global Offices Canada Pakistan Philippines Connect with us and stay in touch Bobby O Neal Director of Sales T: E: bobby.oneal@360factors.com Sajjad Gul Director of Business Development T: E: sajjad.gul@360factors.com Rosanna Lyn Director for Product Management T: E: rosanna.lyn@360factors.com Operational Excellence. Sustainability. Increased Margins. 360factors is a cloud-based Regulatory Risk and Compliance Management Software Company specializing in Oil & Gas, Power & Utilities and Banking & Financial Services industries. 360factors platform, Predict360, uses unique mapping and cognitive technology to provide regulatory insight, predict risks and increase sustainability and margins. Predict360 helps break down silos and overlapping costs through multiple tools to improve operational excellence, visibility to risk and quality data that executives can use to make decisions in a timely manner. Additionally, it provides functional compliance managers with an out-of-the-box solution with industry-specific regulations or standards, workflows and policy & procedure templates so they can perform the day-to-day regulatory and operational risk and compliance tasks at a functional level.
Governance, Risk and Compliance in the Healthcare Industry
Governance, Risk and Compliance in the Healthcare Industry Risk Management as a Competitive Differentiator Overview The way healthcare has operated traditionally will not be the way it will operate in
More informationBig Data Industry Approaches to Operational Excellence
Big Data Industry Approaches to Operational Excellence The Value of Big Data in the Power and Utilities Industry Overview Evolving systems and infrastructure to meet the needs of 21 st century demands
More informationBig Data Approaches to Life Sciences
Big Data Approaches to Life Sciences How big data is changing the way life sciences companies operate Overview As the industry embraces innovation, it is constantly faced with the challenge of meeting
More informationSustainable Environment, Health and Safety as Competitive Differentiator
Sustainable Environment, Health and Safety as Competitive Differentiator Overview The opportunities and risks associated with environment, health and safety (EHS) and sustainability issues are on the rise.
More informationKNOW 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 informationFraud-Related Compliance
Fraud-Related Compliance Areas of Compliance, Part 1: FCPA, SOX, PCAOB, Dodd-Frank 2015 Association of Certified Fraud Examiners, Inc. Foreign Corrupt Practices Act (FCPA) Enacted to prohibit corrupt payments
More informationSimplify 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 informationSEMGROUP CORPORATION. Anti-Corruption Compliance Policy August, 2011
SEMGROUP CORPORATION Anti-Corruption Compliance Policy August, 2011 SCOPE This is a global policy (the Policy ) applicable to the worldwide operations of SemGroup Corporation ("SemGroup") and all of its
More informationLAUREATE ANTI-CORRUPTION POLICY
LAUREATE ANTI-CORRUPTION POLICY Laureate Anti-Corruption Policy 1.0 PURPOSE AND BACKGROUND This Anti-Corruption Policy establishes basic standards and a framework for the prevention and detection of bribery
More informationForeign Corrupt Practices Act Summary and Policy
I. Introduction/Overview Foreign Corrupt Practices Act Summary and Policy It is the policy of Cantel Medical Corp. and its subsidiaries (the Company ) to comply with all applicable laws, rules and regulations,
More informationANTI-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 informationPROTIVITI 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 informationHILLENBRAND, INC. AND SUBSIDIARIES. Global Anti-Corruption Policy Statement and Compliance Guide
HILLENBRAND, INC. AND SUBSIDIARIES Global Anti-Corruption Policy Statement and Compliance Guide Hillenbrand, Inc., including all of its subsidiaries (referred to collectively as the Company ), maintains
More informationFRANCHISORS AND FRANCHISEES: UNDERSTANDING COMPLIANCE RISKS
FRANCHISORS AND FRANCHISEES: UNDERSTANDING COMPLIANCE RISKS Franchisors and Franchisees: Understanding Compliance Risks What do KFC, Liberty Tax Service, Fatburger, and Orkin have in common? In addition
More informationTHOMSON REUTERS ACCELUS. The FCA: A Game Changer
THOMSON REUTERS ACCELUS The FCA: A Game Changer for Company Training Statement of intent This whitepaper, brought to you by Thomson Reuters, discusses the implications of the new financial regulatory framework
More informationFOREIGN CORRUPT PRACTICES ACT POLICY for PROJECT PROFESSIONALS GROUP PTY. LTD.
FOREIGN CORRUPT PRACTICES ACT POLICY for PROJECT PROFESSIONALS GROUP PTY. LTD. 1.0 Purpose and Scope of this Manual The purpose of this Policy is to ensure compliance by Project Professionals Group Pty.
More informationOMNI TECHNICAL SOLUTIONS. Business Ethics, Compliance, Anti-Corruption and Anti-Money Laundering Policy
OMNI TECHNICAL SOLUTIONS Business Ethics, Compliance, Anti-Corruption and Anti-Money Laundering Policy Updated: September 2015 Table of Contents 1. Introduction... 2 2. Business Ethics... 3 2.1 Compliance...
More informationForeign Corrupt Practices Act. The Rationale behind the Implementation of the FCPA
Surname 1 Name: Instructor: Course: Date: Foreign Corrupt Practices Act The Rationale behind the Implementation of the FCPA The foreign corrupt practices act, or FCPA for short, was enacted in 1997. During
More informationCARDINAL RESOURCES LLC INTRODUCTION
CARDINAL RESOURCES LLC ANTI- BRIBERY AND ANTI- CORRUPTION POLICY INTRODUCTION The purpose of this Anti- bribery and Anti- corruption Policy (the "Policy") is to ensure compliance by the Red Bird Group
More informationU.S. Foreign Corrupt Practices Act for Beginners
U.S. Foreign Corrupt Practices Act for Beginners This presentation, related materials and subsequent discussion are provided for educational purposes only. They do not constitute legal advice nor do they
More informationERIN ENERGY CORPORATION. ANTI-CORRUPTION COMPLIANCE POLICY Effective Date: 10/1/2011
ERIN ENERGY CORPORATION ANTI-CORRUPTION COMPLIANCE POLICY Effective Date: 10/1/2011 Statement of Policy It is the policy of Erin Energy Corporation, (the Company ) to conduct its worldwide operations ethically
More informationThe 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 informationAPEC 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 informationM&A in 2015: Successor Liability Under the FCPA. Norton Rose Fulbright US LLP Thursday, February 26, 2015
M&A in 2015: Successor Liability Under the FCPA Norton Rose Fulbright US LLP Thursday, February 26, 2015 Speaker Marsha Z. Gerber Partner Norton Rose Fulbright US LLP Marsha Gerber is a partner in the
More informationCorporate Code of Conduct
Corporate Code of Conduct Statement of Policy. It is the policy of Casa Mining Limited (the "Company") that all of its officers, directors, employees, contractors, consultants and agents representing the
More informationPEPs and the FCPA. Presented to 10 th Puerto Rican Symposium of Anti Money Laundering. February 28 March 1, 2013
PEPs and the FCPA Presented to 10 th Puerto Rican Symposium of Anti Money Laundering February 28 March 1, 2013 by Jay Perlman, Director Global Investigations & Compliance, Navigant Table of Contents I.
More informationPlatform 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 information2016 The global ABB integrity program. www.abb.com/integrity
2016 The global ABB integrity program www.abb.com/integrity Tone from the Top Don t Look the Other Way A culture of integrity is a prerequisite for a world-class business. Many valuable customers choose
More informationFCPA and International Compliance
FCPA and International Compliance Briefing to San Antonio Post, SAME C. Ernest Edgar IV General Counsel, Atkins North America 1 Agenda Understanding the FCPA The Nuts and Bolts of the FCPA Who Is Covered
More informationDIGITAL RIVER, INC. FOREIGN CORRUPT PRACTICES ACT AND ANTI-BRIBERY POLICY. (Adopted by resolution of the Board of Directors on December 1, 2011)
DIGITAL RIVER, INC. FOREIGN CORRUPT PRACTICES ACT AND ANTI-BRIBERY POLICY (Adopted by resolution of the Board of Directors on December 1, 2011) Digital River, Inc. and our affiliates ( DR ) must comply
More informationAnti-Bribery Provisions of the Foreign Corrupt Practices Act: Application to Foreign Corporations and Individuals
Anti-Bribery Provisions of the Foreign Corrupt Practices Act: Application to Foreign Corporations and Individuals LeClairRyan Carlos F. Ortiz 973.491.3365 carlos.ortiz@leclairryan.com Valerie C. Charles
More informationWHITE PAPER Third-Party Risk Management Lifecycle Guide
WHITE PAPER Third-Party Risk Management Lifecycle Guide Develop and maintain compliant third-party relationships by following these foundational components of a best-practice assessment program. Third
More informationPROTIVITI 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 informationWhat does it mean for Non-US Companies?
White Paper FCPA Enforcement What does it mean for Non-US Companies? September 2012 Last updated July 2014 Table of Contents FCPA enforcement: What does it mean for Non-US Companies? 3 International scope
More informationSupplier Anti-Corruption and Anti- Bribery Policy
Supplier Anti-Corruption and Anti- Bribery Policy 2014 Dwellworks Contents Purpose and Scope... 3 Core Principles... 4 Guidelines for Anti-Corruption and Anti-Bribery Compliance... 5 Applicable Definitions...
More informationCHARTER FOR THE THE REGULATORY, COMPLIANCE & GOVERNMENT AFFAIRS COMMITTEE CHARTER THE BOARD OF DIRECTORS
CHARTER FOR THE THE REGULATORY, COMPLIANCE & GOVERNMENT AFFAIRS COMMITTEE CHARTER OF THE BOARD OF DIRECTORS OF Copyright/permission to reproduce Materials in this document were produced or compiled by
More informationAmgen GLOBAL CORPORATE COMPLIANCE POLICY
1. Scope Applicable to all Amgen Inc. and subsidiary or affiliated company staff members, consultants, contract workers and temporary staff worldwide ( Covered Persons ). Consultants, contract workers,
More informationImplementing a Third-Party Management Solution: 5 Steps for Success
Implementing a Third-Party Management Solution: 5 Steps for Success Centralizing third-party management and automating the compliance process is a vital step towards achieving Anti-Bribery and Anti-Corruption
More information30 Important Considerations for Effective FCPA Compliance
30 Important Considerations for Effective FCPA Compliance Effective design, good-faith implementation As enforcement of the Foreign Corrupt Practices Act (FCPA) has gone through the roof in recent years,
More informationThe Foreign Corrupt Practices Act Navigating a regulatory minefield. PricewaterhouseCoopers LLP 1
The Foreign Corrupt Practices Act Navigating a regulatory minefield PricewaterhouseCoopers LLP 1 2 PricewaterhouseCoopers LLP Introduction In recent times, two parallel trends have combined to increase
More informationChambers General Counsel Seminar
Chambers General Counsel Seminar FPCA: Current Challenges for In-House Counsel Gregory Kehoe Greenberg Traurig Michael Marinelli Greenberg Traurig Ernest Edgar Atkins North America Why is FCPA Important
More informationComplying with the U.S. Foreign Corrupt Practices Act
Complying with the U.S. Foreign Corrupt Practices Act 1. About This Manual This Manual describes the Foreign Corrupt Practices Act ( FCPA ), 15 U.S.C. 78m, 78dd, 78ff (collectively, FCPA ), anti-corruption
More informationDRAFT. Anti-Bribery and Anti-Corruption Policy. Introduction. Scope. 1. Definitions
DRAFT Change History: Anti-Bribery and Anti-Corruption Policy Control Risks Group Ltd Commercial in confidence Introduction This document defines Control Risks policy on the avoidance of bribery and corruption.
More information{>> 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 informationWorldwide 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 informationMACLEAN-FOGG COMPANY FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY
MACLEAN-FOGG COMPANY FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY MacLean-Fogg s corporate policy prohibits all improper or unethical payments to government officials anywhere in the world. This is
More informationPHOENIX 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 informationThe Latest Wave of Securities Enforcement Actions And What To Do About It
The Latest Wave of Securities Enforcement Actions And What To Do About It Robert Kent Chicago, IL 6 June 2012 Regulatory and Enforcement Environment Regulatory and Enforcement History Looking Back on a
More informationSecurities Litigation Alert The Foreign Corrupt Practices Act: The Next Corporate Scandal?
Securities Litigation Alert The Foreign Corrupt Practices Act: The Next Corporate Scandal? January 28, 2008 by christopher j. steskal As the stock option backdating cases wind down, what will be the next
More informationForeign Corrupt Practices Act Policy August 19, 2015
I. PURPOSE To provide guidelines to all officers, directors, employees, consultants and agents that are employed by the Company to ensure compliance with the Foreign Corrupt Practices Act of the United
More informationReducing Regulatory Risk in an Era of Intensified Enforcement
WHITE PAPER Reducing Regulatory Risk in an Era of Intensified Enforcement Best Practices for Building a Comprehensive Compliance Program By Kelvin Dickenson Compliance is even more critical as governments
More informationTHE FOREIGN CORRUPT PRACTICES ACT: AN OVERVIEW
THE FOREIGN CORRUPT PRACTICES ACT: AN OVERVIEW 1 This white paper summarizes some of the key points, considerations, and factors when faced with a Foreign Corrupt Practices Act matter. As with any overview,
More informationLANTHEUS 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 informationSTATEMENT 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 informationANTI-CORRUPTION AND ANTI-BRIBERY POLICY
COMPLIANCE 18.0 ANTI-CORRUPTION AND ANTI-BRIBERY POLICY I. SCOPE This policy applies to all directors, officers, employees, agents, and shareholders of UHS of Delaware, Inc. (hereafter, UHS ), its subsidiaries
More informationAnti-Corruption and FCPA Compliance Policy
Anti-Corruption and FCPA Compliance Policy Purpose and Scope Vicor Corporation ( Vicor or the Company ) must comply with the U.S. Foreign Corrupt Practices Act of 1977, as amended (the "FCPA") and all
More informationForeign business partners under the FCPA
Foreign business partners under the FCPA by Tom Fox 1 TITLE about the writer Thomas Fox has practiced law in Houston for 25 years. He is now assisting companies with FCPA compliance, risk management and
More informationFifth 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 informationA Comparison of the U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act
October 2010 A Comparison of the U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act BY MICHELLE DUNCAN, PALMINA FAVA & SAMANTHA KAKATI Introduction The U.S. is the global leader in enforcing anti-corruption
More informationCOMPLIANCE: THE NEW INTERNATIONAL LAW
COMPLIANCE: THE NEW INTERNATIONAL LAW Theodore L. Banks AUTHOR Theodore Banks is a partner at Scharf Banks Marmor LLC in Chicago, and President of Compliance & Competition Consultants, LLC. He is the editor
More informationELEPHANT TALK COMMUNICATIONS CORP. FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY
ELEPHANT TALK COMMUNICATIONS CORP. FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY I. POLICY STATEMENT This Foreign Corrupt Practices Act Compliancy Policy (the Policy ) has been adopted by Elephant Talk
More informationANTI-CORRUPTION COMPLIANCE GUIDELINES
ANTI-CORRUPTION COMPLIANCE GUIDELINES INTRODUCTION These guidelines establish procedures for handling, and should help you identify anti-corruption concerns. If you are ever uncertain or feel uneasy about
More informationHow To Write An Anti Corruption Policy For A Company
Declaration of the strategic position with respect to anticorruption and anti-bribery practices Anti-corruption and Anti-bribery policy January, 2015 Table of Contents Justification... 3 1. Purpose...
More information15 December 2015. Crime Prevention and Anti-Fraud Policy
15 December 2015 Crime Prevention and Anti-Fraud Policy Content 1. Purpose 3 2. Scope 3 3. Action Principles 3 4. Control, Evaluation, and Revision 4 Look after the Environment. Print in black and white,
More informationACCELUS COMPLIANCE MANAGER FOR FINANCIAL SERVICES
THOMSON REUTERS ACCELUS ACCELUS COMPLIANCE MANAGER FOR FINANCIAL SERVICES PROACTIVE. CONNECTED. INFORMED. THOMSON REUTERS ACCELUS Compliance management Solutions Introduction The advent of new and pending
More informationDeloitte Forensic. Deloitte Forensic. Capability Statement
Deloitte Forensic Deloitte Forensic Capability Statement Deloitte named a Kennedy Vanguard Leader in Forensic Investigation Consulting, based on capabilities. Source: Kennedy Consulting Research & Advisory;
More informationAt Risk. In this Issue: Avoiding a world of hurt: Knowing your counterparties before you engage. Volume 8, No. 1. kpmg.ca/atrisk.
At Volume 8, No. 1 In this Issue: Avoiding a world of hurt: Knowing your counterparties before you engage Regulatory Threats Operations Emerging Markets Management Canadian Organizations Supply Chains
More informationOur vision. A company where the best people want to work.
Code of Conduct Our vision A company where the best people want to work. The world leader in chemical distribution, providing unparalleled connectivity between customers and suppliers. 2 Univar s guiding
More informationTHOMSON REUTERS ACCELUS
THOMSON REUTERS ACCELUS ACCELUS Screening Resolution Service Executive Summary Thomson Reuters Accelus offers Screening Resolution Service (SRS): an outsourced screening service for Corporates and Financial
More informationCC255 C O R P O R A T E. Altus FCPA Policy. Last revised: 12 October 2010
CC255 Altus FCPA Policy Last revised: 12 October 2010 C O R P O R A T E Foreign Corrupt Practices Act Policy Purpose The purpose of this Policy is to ensure compliance by Altus and its directors, officers,
More informationNCI BUILDING SYSTEMS, INC. FOREIGN CORRUPT PRACTICES ACT POLICY STATEMENT AND COMPLIANCE GUIDE
NCI BUILDING SYSTEMS, INC. FOREIGN CORRUPT PRACTICES ACT POLICY STATEMENT AND COMPLIANCE GUIDE Introduction The Foreign Corrupt Practices Act as amended by the International Anti-bribery and Fair Competition
More informationCutting-Edge Third Party Risk Management
Cutting-Edge Third Party Risk Management SCCE Utilities & Energy Compliance & Ethics Conference Flora A. Francis Compliance Counsel Flow & Process Technologies GE Oil & Gas Houston, Texas February 25,
More informationWhite Paper: The Seven Elements of an Effective Compliance and Ethics Program
White Paper: The Seven Elements of an Effective Compliance and Ethics Program Executive Summary Recently, the United States Sentencing Commission voted to modify the Federal Sentencing Guidelines, including
More informationApplication of the Foreign Corrupt Practices Act in China
Application of the Foreign Corrupt Practices Act in China Introduction U.S. companies and their subsidiaries in China must have an adequate Foreign Corrupt Practices Act ( FCPA ) compliance program. Doing
More informationForeign Corrupt Practices Act & Compliance Policy
Team Resources Management () INTEGRITY MANAGEMENT SYSTEM (IMS) Printed documents are considered uncontrolled. Controlled documents can be found on the Atlantica server. -2-POL-057 1 0 02-Dec-2013 1 of
More informationThe Foreign Corrupt Practices Act: A Primer. Mark Srere Paul Huey-Burns Anita Esslinger May 12, 2011
The Foreign Corrupt Practices Act: A Primer Mark Srere Paul Huey-Burns Anita Esslinger May 12, 2011 Today's Presenters Anita Esslinger Paul Huey-Burns Mark Srere 2 Topics of Discussion Relevance Overview
More informationANTI-BRIBERY AND CORRUPTION POLICY
ANTI-BRIBERY AND CORRUPTION POLICY OBJECTIVES Woodside is committed to conducting its business and activities with integrity. To achieve this objective: Woodside will not engage in corrupt business practices;
More informationHow Hedge Funds and Private Equity Firms Can Manage Foreign Corrupt Practices Act Risks
How Hedge Funds and Private Equity Firms Can Manage Foreign Corrupt Practices Act Risks Edward T. Kang and Brian D. Frey of Alston & Bird LLP In recent years, the Department of Justice (DOJ) and the Securities
More informationANTI BRIBERY AND FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY
ANTI BRIBERY AND FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY THIS POLICY DOES NOT CREATE A CONTRACT OF EMPLOYMENT OR ALTER THE AT WILL NATURE OF ANY EMPLOYEE S EMPLOYMENT IN ANY WAY. 1. Statement of
More informationAdministrative 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 informationAn Oracle White Paper October 2009. An Integrated Approach to Fighting Financial Crime: Leveraging Investments in AML and Fraud Solutions
An Oracle White Paper October 2009 An Integrated Approach to Fighting Financial Crime: Leveraging Investments in AML and Fraud Solutions Executive Overview Today s complex financial crime schemes pose
More informationMANNING & NAPIER, INC. FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY
MANNING & NAPIER, INC. FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY Purpose The purpose of this Foreign Corrupt Practices Act Compliance Policy (this Policy ) is to help ensure compliance by Manning
More informationCompliance Management, made easy
Compliance Management, made easy LOGPOINT SECURING BUSINESS ASSETS SECURING BUSINESS ASSETS LogPoint 5.1: Protecting your data, intellectual property and your company Log and Compliance Management in one
More informationTHE BRIBERY ACT2010. Quick start guide
THE BRIBERY ACT2010 Quick start guide The Bribery Act 2010 modernises the law on bribery. It comes into force on 1 July 2011. This document offers a quick guide to the things you need to know to prepare
More informationThe US Foreign Corrupt Practices Act guidance published by US government
Briefing The US Foreign Corrupt Practices Act guidance published by US government Summary US government guidance provides helpful collection of principles and case law, but does little to clarify areas
More informationFCPA Compliance: An Ounce of Prevention.
FCPA Compliance: An Ounce of Prevention. Michael E. Burke Arnall Golden Gregory LLP Washington, DC +1.202.677.4046 Mike.Burke@agg.com Webinar Overview Today s Discussion FCPA Overview Recent Trends in
More informationFOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY
PURPOSE POLICY FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY This Policy ensures that China Xiniya Fashion Limited ( Xiniya ) complies with the Foreign Corrupt Practices Act 1977 ( FCPA ). Penalties
More informationA Summary of U.S. Law Against the Bribery of Foreign Officials:
Fall Winter 2005 A Summary of U.S. Law Against the Bribery of Foreign Officials: The U.S. Foreign Corrupt Practices Act The U.S. Foreign Corrupt Practices Act (the FCPA ) prohibits corrupt payments to
More informationFraud and the Government Internal Auditor
Fraud and the Government Internal Auditor January 2012 Fraud and the Government Internal Auditor January 2012 Official versions of this document are printed on 100% recycled paper. When you have finished
More informationFCPA COMPLIANCE: THE BENEFITS OF AUTOMATING THIRD-PARTY DUE DILIGENCE
MED 2 Brand Profile Integrated M Event Offerin Editorial Cale Media Specs FCPA COMPLIANCE: THE BENEFITS OF AUTOMATING THIRD-PARTY DUE DILIGENCE EXECUTIVE SUMMARY In today s global business climate, organizations
More informationExhibit B SUMMIT ESP, LLC POLICY RELATED TO COMPLIANCE WITH THE UNITED STATES FOREIGN CORRUPT PRACTICES ACT
Exhibit B SUMMIT ESP, LLC POLICY RELATED TO COMPLIANCE WITH THE UNITED STATES FOREIGN CORRUPT PRACTICES ACT Summit ESP, LLC and any related companies (collectively Summit ) will conduct its business transactions
More informationAnti-Money Laundering controls in Mergers & Acquisitions
White Paper Anti-Money Laundering controls in Mergers & Acquisitions June 2014 Anti-Money Laundering controls in Mergers & Acquisitions Authors: Ana L. Pereira and Ana Maria H. de Alba Caveat emptor let
More informationForeign Corrupt Practices Act (FCPA)
Compliance Guideline Foreign Corrupt Practices Act (FCPA) Dachser GmbH & Co. KG Introduction The purpose of this guideline is to provide employees of DACHSER GmbH & Co. KG ( DACHSER ) involved in international
More informationKnowing your customers and their customers and their customers and so on and so on
Knowing your customers and their customers and their customers and so on and so on Identifying your Third-Party s and their Nested s This ACH risk management white paper provides an overview of ACH relationships
More informationAGA Kansas City Chapter Data Analytics & Continuous Monitoring
AGA Kansas City Chapter Data Analytics & Continuous Monitoring Agenda Market Overview & Drivers for Change Key challenges that organizations face Data Analytics What is data analytics and how can it help
More informationMAY 20, 1981. Introduction. MR. CHAIRMAN and members of the committee, as Ambassador Brock testified, we agree with
STATEMENT OF SHERMAN E. UNGER, GENERAL COUNSEL, U.S. DEPARTMENT OF COMMERCE BEFORE THE SUBCOMMITTEE ON INTERNTAIONAL FINANCE AND MONETARY POLICY AND THE SUBCOMMITTEE ON SECURITIES OF THE SENATE BANKING,
More informationBusiness Principles September 2014
Business Principles September 2014 1. INTRODUCTION 2. BUSINESS PRINCIPLES 2.1 Core Principle We behave honestly, fairly and with integrity 2.2 Overarching Principle We manage risk and seek to continually
More informationIntroduction to the Foreign Corrupt Practices Act (a training presentation for employees)
Introduction to the Foreign Corrupt Practices Act (a training presentation for employees) Introduction Thank you for participating in our Foreign Corrupt Practices Act (FCPA) training program. [Our Company]
More informationAnti-corruption compliance program
Anti-corruption compliance program Table of contents 1 Introduction...7 2 Ethics Code of Conduct and Anti-corruption...8 3 The Norwegian penal code against corruption...12 4 The U.S. Foreign Corrupt Practices
More informationGuidance 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