FCPA and Bribery Act Compliance in the Global Supply Chain

Auszug au dem FCPA Compliance and Ethics Blog von Thomas R. Fox: Ed. Note-recently speaks to Harriet O’Brien, Program Director for Compliance in the Global Supply Chain, spoke with Adrian Mebane, Director of the Ethics and Compliance Group for Weatherford International Ltd., on issues relating to compliance in the global supply chain. With permission, we reprint the issue on this posting. Why is it important to focus on compliance in the context of the global supply chain?

In the various countries in which we operate, we’re always on the lookout for particular supply chain issues, specifically as they relate to procurement activities. We may encounter individuals not abiding by our procurement policy; either the global procurement policy that’s in place or the procurement policies in respective countries. By that I mean that vendors and/or suppliers may not have been selected appropriately, in that the business neglected to follow competitive bidding practices such as failing to obtain three quotes/bids or failed to have a clear segregation of duties. These practices can lead to an individual selecting a vendor or supplier in which they may have some sort of ownership interest or by showing preferential treatment to a company in which that individual’s family or friends may work. These conflicts of interest can potentially lay a foundation for code of business conduct violations. I’d say that these are some of the prevalent compliance issues companies’ encounter from a supply chain context.

Whilst these types of incidents thankfully do not expose companies to the same level of risk as other forms of corruption like improper payments and gifts to government officials in order to obtain or retain business, they certainly can create headaches to operations and impact its bottom line ...

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