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Building a Global Compliance Program

2013 Global Ethics Summit. Building a Global Compliance Program. March 6, 2013. Particular 2013 Focus.

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Building a Global Compliance Program

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  1. 2013 Global Ethics Summit Building a Global Compliance Program March 6, 2013

  2. Particular 2013 Focus • A heavy focus on training is necessary, particularly in regard to FCPA and the UK Bribery Act.  This training should be widespread across all regions in which company operates and in translated into different languages.  • Companies are focusing a lot on anonymous hotline rollout to international clientele around it so that it meets the works council compliance issues.  Particular focus on hotline comes from whistleblower rewards from the SEC, and incentives for employees to report issues to outside parties before reporting to the compliance office. • The Code of Conduct is the foundational pieces used to globalize and adapt from North America to global compliance model.  Also conducting risk assessments – putting together cross sections of 30 – 40 employees in the region and ask them to assess likelihood and probability of risk – is important element.

  3. Particular 2013 Focus (cont’d) • Addressing industry-specific risk is essential when developing programs – this means drawing particular focus on policy and training programs that help to mitigate these risks. • Example given in the engineering/construction industry, in which a new compliance program roll out includes heavy focus on anti-corruption and anti-boycott controls. • Compliance programs can be developed by a compliance council in order to effectively bring together insight from compliance professionals around the world. • An online component to training is a big piece of a contemporary compliance program.

  4. Particular 2013 Focus (cont’d) • Real time audit teams can be used to constantly look for potential problems within a companies compliance program. If/when these audit teams discover issues, companies must perform proactive analysis to conduct potential problems. • When creating an anti-corruption program, companies should look toward the UK Bribery Act for guidance in certain areas, particularly in regard to its prohibition of facilitation payments, which is more strict in this regard than the Foreign Corrupt Practices Act. • Third party risk should be a focus of a compliance program because of liability to organization from supply chain, agents, JVs, etc.

  5. Not Just for Financial Institutions • When employees travel overseas, particularly to countries such as China, they should be apprised of the UK Bribery Act, and understand that many of the third parties/business executives in the country are also Chinese officials.

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