As compliance programs mature, it is becoming increasing clear that one size does not fit all. Moreover, there may be several different approaches to creating the most effective compliance program for your organization. This past week I attended the ACI FCPA Boot Camp in Houston. Many of the presentations dealt programs, procedures and process companies had developed specifically for the compliance issues they have faced around the globe. One of these was in a session entitled “Compliance Programs 2.0” where one of the subjects discussed was who to embed as a local compliance representative in an international business unit.
On this discussion panel were two lawyers, Rick Chapman, Assistant General Counsel at Halliburton and John Lewis, Sr. Managing Counsel – Compliance Global Anti-Bribery Counsel, they presented two distinct views on utilizing local compliance point persons in their company’s respective international anti-corruption and anti-bribery efforts. I found that each company’s approach had merit and that they are both models which you can review to determine which might be best suited for implementation in your organization.
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