In an article entitled “Walking a Beat to Reduce Corruption”, Moritz analogized “the concept of community policing that has been used to reduce crime in many major cities across the world” in his innovative approach of “a growing corporate culture of mutual transparency that is having a very positive effect on overall awareness regarding anti-corruption” for third party due diligence under both the FCPA and UK Bribery Act. Moritz talked about community policing in the context of new thinking which holds that more “successful third-party anti-corruption programs depend upon effective two-way communication between the company and its third parties.” He advocates that companies “engage directly with third parties to build trust” and to communicate a company’s ethical values to both those third parties in its Sale and Supply Chains. The starting point for any trust is communications. He believes that for a compliance program to be truly effective, “it must create communication channels between compliance, its internal clients within the organization and the third parties whose actions could lead to corruption liability.” This communication should begin by making a company’s key employees, whose responsibilities include engagement with third parties i.e. business sponsors, “to the potential risks of these commercial relationships, how to recognize them, what they may mean in terms of their continuing compliance obligations and how to convey this information to the third parties in a way that is not construed to be offensive in any way.”
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