The u. S. Foreign corrupt practices act implications for international distributors

Focus on PREVENTION and EARLY DETECTION

• Focus on PREVENTION and EARLY DETECTION
• ▪ Focus here on contractual relationships: Acquisition needs higher level of due diligence, preventative reps & warranties, exclusions
• First: Get own house in order
• ▪ Written anti-corruption / anti-bribery / ethics policies IN HOUSE
• ▪ Training of corporate employees
• Policies without implementation worthless
• ▪ Internal accounting controls to detect oddities which could = bribes
• ▪ Targeted industries exercise special care

• Achieving Compliance – Preparation