Provenance in the Supply Chain: Transparency and Accountability under the FCPA and Bribery Act


In the October 2010 issue of the Harvard Business Review there is a Spotlight article on “The Transparent Supply Chain”. In this article, author Stephen New discusses the evolution in Supply Chain from opaqueness to transparency and focuses on the “quality, safety, ethics and environmental impact” of the Supply Chain on the triumvirate of companies, customers and government. New terms this information as “Provenance” and this is relevant both up and down the Supply Chain.

New points out that customers are becoming increasingly concerned with not only the authenticity of the goods they purchased but also the ethics of how the goods were manufactured in the Supply Chain. Companies have long been concerned with the quality of goods and services they receive from their Supply Chain vendors and tracking this information can provide assurances of high quality control. Increasingly the third prong of the triumvirate, the government, is now requesting such information and such transparency in the area of anti-corruption and anti-bribery compliance.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Thomas Fox, Compliance Evangelist | Attorney Advertising

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