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Third-Party Relationships Ethics

Procurement Pressure: The Convergence Of Supply And Compliance

by Thomas Fox on

With a growing number of complex regulations and directives, the only thing that is constant right now in the regulatory environment is change. Supply chain leaders and compliance professionals alike continue to grapple with...more

Group-Level Accountability for Third-Party Risk: Why It’s So Hard

by NAVEX Global on

Of the wide range of challenges that compliance officers face with third parties, my favorite is: who “owns” third-party risk management? The truth is that different people within the enterprise feel different types of pain...more

Coordinating Third Party Due Diligence and Procurement

by Michael Volkov on

Third party risk management is easily one of the most challenging risks for compliance officers. With all the attention and hype surrounding third party risk, companies have marshaled attention and resources to mitigate the...more

Hallmark 2 – Code of Conduct and Compliance Policies and Procedures

by Thomas Fox on

The cornerstone of a Foreign Corrupt Practices Act (FCPA) compliance program is its written protocols. This includes a Code of Conduct, policies and procedures. In the FCPA Guidance, the Department of Justice (DOJ) and...more

Third Party Risk Management: Balancing Due Diligence Screening and Monitoring

by Michael Volkov on

In response to aggressive FCPA enforcement and recurring problems with third parties, companies have spent substantial resources and time to design and implement comprehensive ethics and compliance programs. A key part of...more

FCPA Compliance and Ethics Report-Episode 91, Internal Controls for Third Parties Under the FCPA, Part II

by Thomas Fox on

In this episode, I continue my exploration of internal controls around third parties in a FCPA compliance program, with Henry Mixon. ...more

Internal Controls for Third Party Representatives in a FCPA Compliance Program

by Thomas Fox on

This week, I am continuing my podcast series, on the FCPA Compliance and Ethics Report, on internal controls in best practices anti-corruption compliance program, under the Foreign Corrupt Practices (FCPA), UK Bribery Act or...more

Thinking Through Risk Rankings of Third Parties

by Thomas Fox on

One question often posed to me is how to think through some of the relationships a company has with its various third parties in order to reasonably risk rank them. Initially I would break this down into sales and supply...more

Termination of a Third Party or Breaking Up Should Not Be Hard To Do

by Thomas Fox on

One of treats each month for the compliance professional is reading the GRC Illustrated column by Carole Switzer, President of the Open Compliance and Ethics Group (OCEG), in the Compliance Week magazine. Not only does...more

FCPA Compliance and Ethics Report-Episode 63-Managing the Third Party Relationship Under the FCPA, Part I

by Thomas Fox on

In this episode I being a two part series on how to manage your third party relationships under the FPCA and UK Bribery Act. In this episode, steps 1-the Business Justification and Step 2-the Questionnaire. ...more

Working With Third Parties In The Due Diligence Process

by Thomas Fox on

On this day we celebrate the 1607 founding of the English colony at Jamestown. While credited with being the first English colony in what became America, it’s probably more accurate to refer to it as the first permanent...more

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