The changing profile of compliance
Auditing third-party service providers for anti-bribery and corruption compliance is the most challenging anti-corruption issue faced by senior compliance officers worldwide, according to the results of a recent survey by KPMG International, as reported in an FCPA Blog post published on September 8.
Less than a third (29 percent) of the 659 respondents from 64 countries say their companies have right-to-audit clauses in contracts with third parties and just 41 percent of those that have such clauses exercise this right, KPMG states in its report, ‘Anti-bribery and corruption: rising to the challenge in the age of globalization’.
Anti-corruption compliance will be the focus of a few sessions at the upcoming Compliance & Ethics Institute, the annual conference of the Society for Corporate Compliance and Ethics (SCCE) and its sister organization, the Health Care Compliance Association (HCCA), to be held in Las Vegas on October 4-7. Risk related to third parties will specifically be addressed in a session called ‘Conducting effective third-party due diligence in China’, being led by Allan Matheson, managing director at Blue Umbrella, a provider of due diligence and pre-employment screening focused on Asia.
The problem of bribery will be examined more broadly in another session called ‘Anti-corruption update for Europe’ led by Sally March, director at Drummond March & Co, and Charles Duross, a partner at Morrison & Foerster. Elsewhere, John Rahie, managing director at Freeh Group International Solutions and a former executive director in General Motors’ legal department, will be on hand with Jeff Killeen, a compliance attorney for investigations at 3M Company, to discuss ‘Global anti-corruption programs: advanced practice and effectively managing risk’.
Attendance at SCCE’s Compliance & Ethics Institute continues to grow by about 20 percent per year, regardless of how well the economy is doing, says Adam Turteltaub, vice president of membership development for SCCE and HCCA. This year, the organizations are expecting more than 1,500 attendees.
‘It’s extraordinary to see the growth of the profession and the increasing complexity of it [with] new issues coming up all the time,’ says Turteltaub. ‘It’s growing ever more international.’ One of the ways compliance is changing is that ‘it’s no longer an adjunct to legal or a small, stand-alone program [and has] become much more integral to the way business is done,’ he adds.
In another session in Las Vegas, Michael Greenberg, director of the RAND Corporation’s Center for Corporate Ethics and Governance, will reflect on the future of compliance and ethics, drawing on the RAND symposium series. ‘RAND is an expert in thinking this through, understanding what’s going on and what the implications are,’ says Turteltaub, who sees compliance becoming ‘much more about communications integration within business processes.’
For more details about what to expect at the Compliance & Ethics Institute, see the timesavers’ guide in Corporate Secretary’s fall issue, out later this month, where you will also find an article entitled Keeping compliance healthy, which considers what the board of directors should be doing to ensure a company’s compliance program is performing as effectively as possible.