Make Sure Your 3rd Parties Have A Compliance Program. If Not, Give Them Yours.

Anti-corruption and due diligence go hand in hand when referring to compliance. Companies that grow and want to expand operations in foreign soil are encouraged to do research on companies, especially if countries are known for having some acts of corruption. The SEC and DOJ are constantly reminding the global business community, in order to be compliant, they must make sure that any company they do business with is also complying with anti-corruption compliance.  In an article by Michael Scher, of the FCPA Blog, he writes of new business entering into South America, particularly in the country of Columbia. Columbia’s reputation for ethical business practices has not always been so clean but with new thinking and [partnerships between public and private sector entities, the countries views of corruption are shifting in a good direction. Joe Murphy, a top compliance expert for the SCCE explains:

"I think it is also true that there is a growing awareness of the importance of compliance and ethics programs in South America, including Colombia. Companies looking to do business [there] should be asking about such programs in their potential partner-companies and helping those who are interested to develop and improve them. We would all benefit from this."

Doing business in different parts of the world does increase your risk for corruption, but as Joe states, companies need to explore and see what kind of programs are in place before creating a business relationship with any company. You should not neglect your company from doing business, if other businesses don’t have policies in place, in fact this would be a prime opportunity to share your policy and procedures, and educate those that are in need of such a compliance program.

Every company needs to know where they are in compliance or they need a starting point from where they can build a solid foundation for a compliance program. Many resources are available and can work as a guideline to help manage and maneuver you in creating such programs. Policies, Procedures, and Records is an important part of any compliance program, click here to learn more