Ready for the Heat Wave - Con Ed's Process in the Compliance Arena

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In the Process Section of the August issue of Wired Magazine is an article by Mike Olsen entitled, “How Con Ed averts blackouts during a heat wave”. Being from Houston and living in one of the hottest summers on record, I was interested in how the electric company in New York City might handle a heat wave and attendant overloading of the Big Apple’s power grid. The article set out the procedures which Con Ed has in place. While noting they were “worthy of NORAD”; the article drove home to me, once again, how important to a process is a Foreign Corrupt Practices Act (FCPA) compliance program.

Con Ed has a five step process to save its electrical grid in an overload situation. These steps are: (1) Recruit, (2) Monitor, (3) Escalate, (4) Make the Call and (5) Shut it Down. These five steps can be critical in a FCPA compliance program. So if your company is in New York, New England or any other place in the United States where an overloaded power grid looms this summer (i.e.: the entire US) perhaps you might consider this process in the context of your FCPA compliance program.

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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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