Peace of mind for you and your pets Friends Forever™
duct foreign transactions to develop
compliance policies and assessments.
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Practical Considerations
This new enforcement environment
highlights the importance of effective
internal controls and policies. While
the U.K.’s Bribery Act includes an adequate procedures defense, the FCPA
does not. Nonetheless, demonstrating that your company has a robust,
good-faith compliance program may
positively affect the outcome of any
enforcement action. With that in mind,
the following are practical steps that
businesses can take to mitigate risk.
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Conduct a risk assessment — know
your markets
Key to developing an effective compliance strategy is conducting a risk assessment of your business activities,
including a review of current business
activities, due diligence procedures,
and internal controls. It should also involve candid conversations with executives and employees in risk-sensitive
areas regarding their day-to-day practices. A critical goal of the risk assessment is to determine how policies and
procedures are implemented, not just
whether they exist.
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Develop clear policies and train on
them
A compliance program should include
clearly articulated policies that are
accessible, audience-appropriate, and
backed up by consequences. The policies should be easily translatable for
use in foreign markets and should be
broad enough to encompass the FCPA,
U.K.’s Bribery Act, and general anti-corruption principles. Employees and
agents should be trained regularly on
the policies and should be included in
the discussion regarding why compliance with the policies is important.
Promote an ethical corporate culture
Corporate culture may be the most
important part of any compliance program. Institutionalizing values that
are consistent with ethical behavior
can go a long way towards lowering
compliance risks. These values should
be demonstrated and reinforced often
by management, which should discuss
compliance programs frequently and
integrate ethics-related policies into
messaging and training.
