Bid Rigging: For Multinationals, More Than Just a Local Law Violation

by Ropes & Gray LLP

Ropes & Gray LLP

Bid Rigging: An Introduction

In many countries, purchases of products or services1 by government or public entities take place primarily through public tenders. The theory behind conducting such tenders is that they will allow the purchasing entity to evaluate competitive bids and to select those that are of the best quality and that represent the best value for money, increasing transparency in the purchasing process and reducing the risk of corruption.

Generally, a public tender begins when a purchasing entity publicly issues a set of tender specifications for the type of product that it wishes to purchase, as well as instructions on how to prepare and submit a bid. After a specified number of bids are submitted or the allotted time for the public tender ends, the end user or a designated tender committee will evaluate the bids and select the one that they find to be the best fit according to defined criteria. Of course, the particular rules and procedures for public tenders vary from jurisdiction to jurisdiction. In China, for example, local law requires that for most purchases made by government entities, the purchasing entity must receive a minimum of three competitive bids and select one bid from among them.

While public tenders have many uses, the significant value of the transactions that are often conducted through these tenders means that participating companies and/or their sales employees have an incentive to try to subvert the process. Therefore, participating companies and the third-party intermediaries that represent them in bidding often try to find ways to ensure that their company’s product is the one selected. This is an activity referred to as “bid rigging.”

The most straightforward type of bid rigging involves collusion between a bidder (either a participating company or a third-party intermediary) and an individual at the purchasing entity who has decided that he or she favors the participating company’s product. In one version of such collusion, the individual at the purchasing entity may assist a bidder to win the bid by issuing technical specifications for the public tender that favor that bidder’s product or make it impossible or unlikely for other products to win. Alternatively, the individual at the purchasing entity may give information about the other bids to a bidder such that the bidder can craft its bid to ensure winning, or allow the bidder to revise its entry despite tender rules prohibiting such behavior.

A somewhat more complicated version of bid rigging is where bidders engage in a system of “accompanying bidders,” in which multiple bidders (or multiple entities affiliated with the same bidder) conspire to determine the outcome of a bidding process. Again, this can be done either by participating companies or by third-party intermediaries acting for them. The most common approach is that one bidder is designated among the colluding parties as the “main bidder” that is intended to win the tender process. The main bidder’s proposal is submitted alongside bids from accompanying bidders that offer inferior products and/or higher pricing to ensure that the main bidder wins the tender, while the requirement of multiple bids for a public tender is nominally satisfied.

Notably, this type of bid rigging may take place with or without knowledge by the purchasing entity. Sometimes, the purchasing entity has chosen which product it would like to purchase, and thus agrees to look the other way while accompanying bidders are organized and not to look too carefully into their bids. At other times, the purchasing entity may not be aware of the plan to present accompanying bidders. In that case, the individual colluding bidders may simply agree amongst themselves that some of them will put in sub-par bids, perhaps in exchange for a fee or with the understanding that the main bidder will in a future tender act as an accompanying bidder in order to repay the favor. In an alternate version of the accompanying bidder scheme, colluding third-party intermediaries may put forward fake bids for companies that are not even aware that the tender is taking place.

Public Tenders and Bid Rigging in Asia

Most countries have laws and regulations on bidding and tenders that prohibit bid rigging. For example, in China – where public tenders are common in industries that involve dealings with state-owned entities (“SOE”) or the use of government funds – the Bidding Law of the People’s Republic of China (“PRC Bidding Law”) issued in 2000 contains express provisions that, amongst others, prohibit:

  • The tenderee disclosing information regarding potential bidders or other information that may affect fair competition;
  • The tenderee disclosing details of minimum bid;
  • The bidders colluding with each other or the tenderee;
  • The bidders paying bribes to the tenderee or the bid evaluation committee;
  • The bidders submitting bids that are lower than cost;
  • The bidders submitting bids in other persons’ names; and 
  • The bidder using other fraudulent or deceptive methods to win the bid.

The prohibitions of the PRC Bidding Law are further clarified in the Regulations on the Implementation of the Bidding Law of the People’s Republic of China (“PRC Bidding Regulations) issued in 2011. For example, “bidders colluding with each other” includes situations where:

  • bidders discuss with each other bidding prices or other substantive contents of the bidding documents;
  • bidders agree on the winning bidder;
  • bidders agree that some bidders would pursue or forego the tender;
  • bidders from the same group or organization agreeing to submit bids in accordance with the group’s or organization’s demands;
  • bidding documents for different bidders are drafted by the same individual or entity;
  • different bidders delegate tender-related affairs to the same individual or entity;
  • different bidders submit bids with suspicious pricing patterns; and
  • different bidders pay bid guarantee deposits from the same entity or bank account.

Violations of the PRC Bidding Law or the PRC Bidding Regulations may result in invalidation of the bid, confiscation of illegal gains, additional monetary penalties, suspension of bidding rights, and revocation of business license. Moreover, if any action violates applicable criminal laws, there may be further criminal liability as well, which includes monetary fines and imprisonment.

In addition to this centralized guidance, there are also industry- and sector-specific rules and regulations regarding tenders with further prohibitions against bid rigging, such as the Construction and Engineering Design Bidding Management Measures for construction projects, and various municipal and/or provincial Measures for the Administration of Centralized Bidding Procurement of Drugs in Healthcare Institutions for drug procurements. Moreover, bid rigging activities may be in violation of laws and regulations governing antitrust and unfair competition, including the Anti-Unfair Competition Law of the People’s Republic of China, and the Anti-Monopoly Law of China.

In Korea, public tenders are also common, as they are required for all construction contracts by central government agencies worth over 200 million won or for goods or services contracts by central government agencies worth over 20 million won, as well as many contracts by local government entities. The Act on Contracts to Which the State is a Party (the State Contract Act) mandates that all participating bidders in public tenders promise not to “offer or receive money, goods, entertainment, or any other benefit directly or indirectly in the course of making or accepting a tender or signing or performing a contract,” and, further, that they make an “integrity agreement” with the tendering entity specifying that the contract may be cancelled if this promise is broken. The State Contract Act further mandates that the determination of the successful bidder shall be made according to certain competitive factors based on price and the criteria specified in the tender notice, and that the bidding be carried out according to the principles of transparency and fairness. A person or entity found to have offered a bribe in relation to a public tender or who has engaged in collusive behavior in relation to such will be restricted from participating in public tenders for all central government agencies for a period of up to two years. Criminal penalties are also possible for involved individuals.

Because numerous situations involving bid rigging have been uncovered in Korea, the country’s Fair Trade Commission (FTC) has implemented a Bid Rigging Indicator Analysis System (BRIAS) designed to identify cases of collusion. For bids above a certain price, BRIAS automatically analyzes data such as bid price as a percentage of the reference price and the number of participants in public tenders, and the method of competition, applying a formula that produces a score intended to show risk of bid rigging. For bids where the score is above a certain threshold, the FTC undertakes further investigation.

Risks of Bid Rigging and Other Public Tender Manipulation

In addition to local law risks, bribes or improper benefits are often provided to either the accompanying bidders or to the end users in connection with these arrangements. Thus, participation in public tenders brings with it an elevated risk of bribery.

In bid rigging cases that involve collusion between a participating company and an end user, these payments will be direct; that is, a payment will be made by the company to an end user to pervert the public tender process. For example, a company may pay a customer to favor that company’s bid in the tender, to issue tender specifications in a manner favorable to the company, to falsify documents, to look the other way in the case of accompanying bidders, or to otherwise corrupt the bidding process in a manner favorable to the Company. Such payments may be cash or may come in the forms of gifts and entertainment provided to customers or tender officials during the tender process.

Where the arrangement of accompanying bidders or other bid rigging behavior is carried out not directly by the company but by a third-party intermediary, the company may make a payment directly to that intermediary that is either passed through to the purchasing entity or—in a case where the purchasing entity is unaware of the accompanying bidder situation—taken by that third-party intermediary as a fee for the service. Alternatively, the cost incurred by a third-party intermediary in making arrangements to win the bid may be considered and allowed for when sales employees at the company offer discounts to that intermediary, and will thus be paid out of that intermediary’s margin.

Practical Case Studies

As early as 1999, the United States Department of Justice had noted that payments as part of a bid rigging scheme may also be corrupt payments that violate the United States Foreign Corrupt Practices Act or local anti-corruption laws. In an unnamed case, U.S. regulators discovered that improper payments were made both to an intermediary to facilitate a conspiracy to rig bids, and to contracting government officials of companies preparing to award contracts, for the purpose of influencing the award decision.

A publicized example that highlights the relationship between bid rigging and corruption is the recent allegations against pharmaceutical bidding agents in Malaysia. In or around June 2018, media sources reported that local bidding agents, with the assistance of international pharmaceutical companies, would engage in bid rigging known as “bid-rotation” to limit competition and take turns to secure supply contracts. The bidding agents allegedly pocketed close to 4 billion Malaysian Ringgits (approximately 990 million USD) through the alleged collusion. Moreover, some of these entities are allegedly close to or owned by Malaysian politicians, high-ranking government officials, and/or their family members. The allegation has led at least one Malaysian MP to urge the central government to cut out tendering agents with regard to public pharmaceutical procurements.

In recent local enforcement matters, we see instances where one bidding agent, with the assistance of international product suppliers, would make improper payments to other bidding agents (who represented either the same supplier or competitor suppliers) in order to secure government procurement contracts on behalf of the international product supplier. In rare instances, the recipient of the improper payments may later be selected – either by chance or on purpose – to sit on the assessment committee of the relevant tenders. As a result of the recipients’ change in status, a payment that may have originally violated only local bidding laws could now be seen by regulators as an improper payment to a government official, which would be in violation of anti-bribery laws as well.

Suggestions for Multinationals

As highlighted above, bid rigging in public tenders is often difficult to detect and may lead to notable adverse consequences for implicated individuals and entities. Therefore, companies should incorporate measures in their internal control framework that help prevent, detect, remediate, and deter bid rigging. These measures may include:

  • Adopting and implementing clear and reasonably detailed policies and procedures regarding public tenders, including specific provisions prohibiting bid rigging and other corrupt conduct;
  • Providing routine and periodic compliance trainings and policy reminders to all staff involved in the public tender process;
  • Maintaining a centralized database to record all public tender activities and documents, and conducting regular reviews of the database to understand statistical trends and look for potential anomalies;
  • Conducting reasonable background checks on and justifying involvement of any third parties (e.g., distributors, agents, etc.) involved in the tender process;
  • Comparing bid quotations to entries in the accounting system to check for discrepancies or anomalies;
  • Regularly monitoring public tender announcements, including the final winning bid/price, and comparing the final bid to internal bid documents;
  • Establishing protocols that seek to fairly and adequately address allegations of bid rigging should such allegations arise;
  • Staying current on industry news and insights to understand new and/or prevalent forms of big rigging practices; and
  • Conducting periodic reviews, possibly with the assistance of professional external advisors, to assess adequacy of existing internal controls and make enhancements where needed.

Although the risk of bid rigging is inherent to public tenders and difficult to eliminate, these and other suitable internal control measures can help mitigate the relevant risks and provide a defense to government regulators. Many multinationals that rely on public tenders as part of their business strategies already have put some, if not all, of the above measures in place, and we urge those that still do not to do the same.

1The behavior discussed in this Alert applies to public tenders both for product purchases and service contracts. For linguistic convenience, however, this alert refers only to product purchases.

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.

© Ropes & Gray LLP | Attorney Advertising

Written by:

Ropes & Gray LLP

Ropes & Gray LLP on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at:

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit
  • New Relic - For more information on New Relic cookies, please visit
  • Google Analytics - For more information on Google Analytics cookies, visit To opt-out of being tracked by Google Analytics across all websites visit This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at:

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.