Implement What You Know with Confidence
Discover action-based tools that provide simple steps for program improvement or robust plans for new ways of doing business.
Your ethics and compliance program is an ecosystem of moving parts. New laws and regulations, new lines of business, new geographies, mergers and acquisitions become part of a growing enterprise that your compliance ecosystem must support.
Effective compliance programs are able to deftly navigate these complexities because they have built strong foundations that were developed with the nature of the compliance industry in mind.
This section will give you the expert advice and programmatic best practices to ensure the first steps you take to develop your program are in the right direction. Or if your program is more mature, these resources and insights will give you the necessary guidance to course correct and improve your program’s foundation at whichever stage it is in.
Chapter 4 of The Worst-Case Scenario Survival Guide for Compliance Professionals
It's no surprise that using third-party agents to support business operations is a common practice around the world. Even with thorough due diligence processes, what would you do if one of your agents was caught in violation of the FCPA? Learn how to survive with Tom Fox.
Chapter 4 of The Worst-Case Scenario Survival Guide for Compliance Professionals
It's no surprise that using third-party agents to support business operations is a common practice around the world. Even with thorough due diligence processes, what would you do if one of your agents was caught in violation of the FCPA? Learn how to survive with Tom Fox.
4. Loop in Your Team
Now that you know of the potential risk to your organization, don’t keep it to yourself. Think of it as being put on notice of a potential FCPA violation. Send an email to your internal audit folks and put the third party on the next audit review. Loop in the business representative to make sure they are communicating your expectations on compliance and ethical business practices. Finally go to your internal controls team to see if there are any detect or prevent controls which might warrant tightening up.
The bottom line: if you are using a sales agent who is caught under a FCPA cloud, you will be on notice for any actions they engage in on behalf of your company.
Illustration by Dex Novak
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