In this article, the third in a continuing series, Homer Moyer discusses the elements of an effective anti-corruption compliance program. While there is no all-purpose check-list for an effective program, there are high-risk areas and company-specific risks that any effective, risk-based program should address. Whether a company's compliance program creates a "culture of compliance" is a standard that obviously goes far beyond simply having a written program. Rather, it requires that the program be understood, accepted, and implemented throughout the company, including locations far-flung from corporate headquarters. These and other dynamics shape how board members should best oversee their company's compliance program.
Click below to access each of the articles in this series.
Board Members, Meet the New FCPA
The Global Transformation in Laws Against Foreign Bribery
To Disclose or Not To Disclose--A Recurring FCPA Question
Costs of FCPA Investigations -- A Board Issue?
Becoming an FCPA-Savvy Director