What is Your FCPA Investigation Protocol?

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Speaking at the IQPC 2010 Internal and Regulatory Investigations in Oil and Gas Conference, Dominic Sheils, Compliance Counsel for John Wood Group PLC, and James W. Noe, Senior Vice President, General Counsel and Compliance Officer for Hercules Offshore, Inc., discussed two different approaches to internal investigation protocols and how these different approaches work for their respective companies. The presentations of Sheils and Noe highlighted the different approaches taken by many companies in the United States and abroad when dealing with the issue of whether to have a written procedure outlining the steps to be taken when a claim which may constitute a bribery or corruption is reported to the company.

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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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