In a compliance utopia, all business would take place within a gated community of noble vendors, unimpeachable business agents, and beyond-reproach sales teams.
That fantasy of comical simplicity is far from modern reality, especially amid increasingly common bribery and corruption threats. There are also the risks inherent in complex supply chains that keep extending upstream, tier-by-tier, like nested dolls.
If the enforcement agencies ever come knocking on your door, you need an anti-corruption program that meets standards and is defensible. But, with abundant reputation risks and potentially massive legal defense costs, what is really needed are programs that prevent corruption in the first place. That was the consensus of an expert panel that participated in a session, “From Defensible to Effective: Anti-corruption Programs,” at the Compliance Week 2018 conference in Washington, D.C., on Monday.
Scott Lane, CEO and chairman of The Red Flag Group, led...