When thinking through a risk assessment around the Foreign Corrupt Practices Act or other anti-bribery law, one thing usually not considered adequately is a company’s sales culture.
Most risk assessments focus on the mechanics and structure of a compliance program, consisting of policies and procedures or whether top managements “gets it.” Yet in many ways the culture around a company’s sales force is one of the key harbingers of potential FCPA risk. A recent article in the Nicosia Business Review considered the sales culture at GlaxoSmithKline PLC under its former (and now convicted) China business unit manager Mark Reilly.
