World Events Like the Olympics and World Cup Can Bring Bribery Risk
Companies know the benefits of exposing themselves to the global market. Big brands, their products and services continue to engage with the world economy and bring new opportunity and growth for these companies. Some of the largest stages in the world, such as the Olympics and the FIFA World Cup, can be ideal opportunities for companies to expand and leverage its growth. These can pose problems as well, as cities need to be able to accommodate the millions of travelers that will be in attendance for these grand events. Companies are eager to gain contracts for the planning and execution of these events and in most cases work with 3rd party business partners/local agents to get these deals done. This does open any company, doing business in this manner, to risk for corruption and bribery. Bilfinger, a German engineering firm, who has paid $32 million for FCPA violations in Nigeria, has launched an internal investigation on possible bribes paid from a subsidiary group related to the 2014 world cup, according to an article by Richard L. Cassin of the FCPA Blog,
“Bilfinger said Sunday that internal information last year showed possible compliance violations in Brazil. The payments were connected with orders to supply monitor walls for security control centers in several big cities. The orders were worth about $6.5 million. Bilfinger hired Ernst & Young and Deloitte and a "specialty" law office in Brazil to determine if employees at affiliate Mauell bribed public officials and employees of state-owned companies.”
Working with 3rd parties will always pose a possible risk for corruption and bribery. Most often companies do have an internal process in place for corruption and bribery cases, but as the risk lay in the subsidiaries you are working with, having an external protocol should be there as well. The SEC and DOJ hold the primary company responsible for any issue related to bribery/corruption. Doing due diligence and educating your business partners to your practices wont eliminate your chances of being exposed to risk, but it will lessen them and show your proactive approach to the issue. Source Intelligence powered by CREATe has developed a series of guidelines that follows FCPA and OECD framework. Our 7 key categories for having a complete anti-corruption program touch on key points from the FCPA framework. To learn more click here.
