FCPA Compliance and Ethics Blog

February 14, 2013

Happy Birthday FT and Welcome Hanson Wade

Yesterday celebrated an auspicious anniversary as it was the 125th anniversary of the British newspaper, the Financial Times (FT), its first issue having been delivered on February 13, 1888. In England, and across the world, the FT is a venerated institution, beginning with its unique color for a print newspaper and, as you might guess from its name, a focus on all things financial. While we in the United States have the Wall Street Journal (WSJ), having a daily newspaper delivered to my door which reports on business, and other noteworthy events from around the world, from a British perspective certainly provides a matchless viewpoint to take a look at events, people and issues. As readers of this blog will recognize I get quite a bit of my material from the FT so it also a very useful resource to me writing about the Foreign Corrupt Practices Act (FCPA); the UK Bribery Act and compliance issues across the globe.

Although, perhaps, not quite as old as the FT, the English company Hanson Wade is putting on a peerless compliance oriented event here in Houston from April 29 to May 2. It is the 3rd annual Oil and Gas Supply Chain Compliance Conference. Once again Hanson Wade will have the top FCPA and related compliance talent in Houston for two days of conferencing and one day of focused workshops. The sessions will feature such topics as the following: New ways to enhance your ability to identify and mitigate the risks posed by third parties by applying some of the creative approaches that GE Oil & Gas and Parker Drilling utilize to ensure compliance across a complex, global supply chain; Ensuring that your company remains compliant when operating in new, challenging locations by applying the latest regional intelligence and develop a practical guide with fresh insights from Fluor, Baker Hughes and Dresser-Rand; Achieving the cross-departmental collaboration that is needed to operate in total compliance;  Hear about the perspectives of compliance and supply chain professionals from Weatherford, Huntsman and Halliburton on how they manage conflicting priorities; Discover the strategies used by Flowserve and Apache to help them prioritize their focus and achieve a higher level of  compliance by quickly and effectively isolating and eliminating weak links in your supply chain; and Benchmarking  your activities against the latest and most innovative approaches used by ExxonMobil, BP, Fluor, KBR and Ensco in how they are delivering continual improvement in their own compliance programs.

Recently Jay Martin, Vice President (VP), Chief Compliance Officer (CCO) and the Senior Deputy General Counsel (GC) for Baker Hughes Incorporated spoke to Hanson Wade about some of the recent issues that have come up for him in his role and what he will be talking about at this year’s event.

Over the last year, what changes have you seen with regard to FCPA implementation and enforcement action by the government? There seems to have been an increased emphasis on the prosecution of individuals as opposed to a sole focus on corporations. There have also been a series of industry sweeps that have been part of the recent enforcement agenda.

How has this highlighted the need for an effective compliance program? The Morgan Stanley case and the recent guidance that was issued by the SEC and the DOJ on the FCPA made clear the importance of a company having a robust compliance program to manage FCPA risk. Recent enforcement actions have given considerable credit to companies that have had such programs and this is the first time we have seen the government actually giving more affirmative credit for good programs.

What one initiative have you implemented this year that allowed you to maximize your compliance program? We are continuously reviewing and upgrading our compliance program based upon new events such as new enforcement cases coming out and the issuance of the DOJ and SEC guidance document.

We are particularly proud of the advancements that we have made with the application of our FCPA compliance program to joint ventures. That has been our biggest initiative.

What are you going to be speaking on at the conference this year? I will be presenting on the different international regulations and how they impact your organization’s compliance program. It is imperative that companies continue to expand and upgrade their compliance programs because of the proliferation of anti-bribery legislation around the globe and the increased cooperation across borders of the enforcement authorities.

So today we celebrate one of the UK’s greatest institution’s the FT. I would only add to the celebration by saying, “Keep on truckin’”. While Hanson Wade is not as old as the FT, they put on, for my money, one of the top compliance events in Houston and use the top compliance talent in Houston, of which there is a considerable amount, to give you insight in to not only what you should do in terms of best practices but also what to expect going forward. I hope that you will mark the dates on your calendar to attend and that I will see you there.

For full details on the Hanson Wade 3rd Annual Oil & Gas Supply Chain Conference, click here. Readers of this blog are entitled to a discount on the registration charge. So use the code FOXLAW13 when registering.

This publication contains general information only and is based on the experiences and research of the author. The author is not, by means of this publication, rendering business, legal advice, or other professional advice or services. This publication is not a substitute for such legal advice or services, nor should it be used as a basis for any decision or action that may affect your business. Before making any decision or taking any action that may affect your business, you should consult a qualified legal advisor. The author, his affiliates, and related entities shall not be responsible for any loss sustained by any person or entity that relies on this publication. The Author gives his permission to link, post, distribute, or reference this article for any lawful purpose, provided attribution is made to the author. The author can be reached at tfox@tfoxlaw.com.

© Thomas R. Fox, 2013

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