One of the things rarely considered is how the investigation triggers the remediation process and the relationship between the two. When issues arise warranting an investigation that would rise to the Board of Directors level and potentially require disclosure to the government, there is usually a flurry of attention and activity. Everyone wants to know what is going on. In an interview with Russ Berland, CCO at Aventiv Technologies, he noted, “for that short moment in time, you have everyone’s full attention.” Yet it can still be “a See more +
One of the things rarely considered is how the investigation triggers the remediation process and the relationship between the two. When issues arise warranting an investigation that would rise to the Board of Directors level and potentially require disclosure to the government, there is usually a flurry of attention and activity. Everyone wants to know what is going on. In an interview with Russ Berland, CCO at Aventiv Technologies, he noted, “for that short moment in time, you have everyone’s full attention.” Yet it can still be “a tricky place because you get your fifteen minutes to get everyone’s full attention, and from then on, you’re fighting with everybody else for their attention, like the normal things in business life.”
Three key takeaways:
1. A serious FCPA allegation gets the attention of the Board and senior management. Use this time to move the compliance program forward.
2. Be aware of how your investigation can impact and even inform your remediation efforts.
3. Be prepared to deal with the dreaded “where else” question. See less -
