FCPA Compliance and Ethics Blog

January 12, 2011

FCPA Compliance in the Global Supply Chain

As readers of this blog know, one of the areas regarding liability under the Foreign Corrupt Practices Act that we have written on is that of liability attaching to a company through its supply chain vendors. (See here, here and here). This issue was clearly at the forefront of the Panalpina settlements, which we also wrote about and the FCPA Professor named “CustomsGate”. There are usually a fair number of conferences and events where the FCPA is the lead topic but rarely do they focus on the Supply Chain so naturally we were intrigued when one such event, occurring in Houston, recently came to our attention. It is a conference entitled, “Compliance in the Global Supply Chain” and it is hosted by Hanson Wade. It will be held on April 26th and 27th in Houston, with Master Workshops both before and after the main conference.

The conference will primarily present industry-known FCPA practitioners, who will provide practical advice on topics specific to the Supply Chain and attendant FCPA liability. Some of the topics which will be covered are listed as:

• How to adapt your policies to comply with both the FCPA and UK Bribery Act: a discussion of the key differences between the two laws and how to reconcile them in your overall compliance framework.

• Clarifying confusion around facilitated payments: which nations allow them and where.

• Create an appropriate framework for conducting risk assessments and due diligence on multiple suppliers: the tangible steps required to create and implement a risk assessment program for vendors.

• Managing the relationship through your contracts: what compliance language to utilize to maintain good relations with your existing suppliers.

• What do you require of your suppliers: learn the nuts and bolts of introducing a supplier code.

• Risk Mitigation through other mechanisms: how to mitigate your exposure to the risks of import/export compliance and ensure you comply with local, regional and international laws.

You can register or find out more about the conference by going to the website address – www.compliance-supplychain.com – as the channel for people to register, and also mention that if they do want to register, to quote the code: FCPA1. There is also an early booking discount of $500.

If you are in Houston, you simply cannot afford to miss this event. If you are in the Supply Chain or procurement, the same holds true. Finally if you are a FCPA compliance practitioner, this is one event which will bring you realistic and effect solutions to your issues. I plan to attend and hope to see you there.

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