Bribery and Compliance in India: Know the Challenge and Prepare for It

by Richard Bistrong, Anti-Bribery Consultant & Speaker

Bribery and Compliance in India: Know the Challenge and Prepare for It

Today I welcome Sherbir Panag, for another post in my series of  country discussions, where we will address Bribery and Anti-Bribery Compliance in India. As a forward, this was an interesting engagement, as it provided me with a opportunity  to ask questions pertaining to the procurement environment in India, as I experienced it during my own work in the field.

RB: Hello Sherbir, thank you for joining me in today’s interview, as we try to share some of the issues confronting employees and corporations who are either working in India or trying to enter the market. But first, perhaps you can share some of your background: 

SP: Hi Richard thank you for the opportunity to discuss compliance and procurement challenges in India. It is a pleasure to be here today.

I am an attorney with MZM Legal, with a focus on business crime, compliance and investigations. I lead my firm’s Criminal Compliance practice where our principal focus is on assisting companies with bribery and other criminal misconduct challenges of India. The scope of my practice besides Indian anti corruption laws, includes working with foreign lawyers on aspects of the U.S. FCPA, UK Bribery Act, German administrative law and other foreign legislation / mechanisms that prevent foreign bribery.

My firm is a member of the Roxin Alliance – an international association of white collar crime lawyers. I am intrinsically involved in all projects of the Roxin Alliance including their working group commitments to the World Bank GFLJD, and I co-head the Alliance’s Administrative Sanctions practice group.

RB: So, lets first address the internal market. What is the current enforcement environment in India with respect to anti-corruption laws, and has that changed in recent years?

SP: The enforcement environment has dynamically changed over the last 3-4 years in India as a powerful social coalition of proactive media houses and civil society has ensured that fighting corruption remains a mainstream issue. Law enforcement authorities and the political establishment see themselves being under greater scrutiny, which has impacted the perception against corruption and the enforcement numbers positively.

The higher judiciary in India has also played an important role in keeping law enforcement on track against corruption. The Supreme Court has resorted to day to day monitoring of certain high profile corruption cases, while also taking suo moto cognizance of matters and reprimanding the executive on its failure to prevent corruption or institute anti corruption initiatives.

Further, reports of foreign law enforcement action with respect to foreign bribery in India has forced the Indian authorities to take up these matters in India as well. The recent example being the AgustaWestland case where an Italian investigation,  reported by the Indian press resulted in India commencing an investigation and subsequently terminating a Euro 556 Million contract, while AgustaWestland’s corruption case is still ongoing.

While empirical data is far from being ideal at the moment, one can reasonably say that the enforcement climate of ‘no enforcement’ or ‘compromised enforcement’ has seen a positive dent.

RB: Do you see a focus on individuals, corporations, or both?

SP: The focus of law enforcement in India has been primarily on individuals. Even in cases involving corporations, the corporation being an accused aside – the authorities have seeked to determine the individuals behind the corporate veil. This slightly traditional prosecution approach stems from the fact that corporate criminal liability has only recently been recognized by the Supreme Court of India.

Legislative changes have been proposed to enhance the liability of companies in corruption related offences, which would bring companies into a potentially greater spotlight with law enforcement authorities. The Prevention of Corruption (Amendment) Bill, 2013 seeks to establish a substantive offence for bribery by a commercial organisation, and also provides that when a commercial organisation is found guilty of the offence of bribery, all such persons who at the time at which the offence was committed were responsible or in charge of conducting the business of the organisation will also be guilty of the offence. The Bill concurrently establishes a compliance defence, which would be a first in India.

RB: Do you think that the enforcement resources are sufficient to promote and enforce current regulations? In other words, are the laws “on-the-books” but unlikely to be aggressively enforced? Again, here I speak of internal bribery as well as enforcing corruption laws governing overseas conduct.

SP: Richard, when it comes to anti corruption enforcement India takes a beating owing to a multitude of factors chief among them being the lack of political will in my view. Appointments to anti corruption enforcement bodies have a high degree of political involvement, which is coupled with insufficient resources in the hands of our authorities in terms of both manpower and technology. Furthermore, enforcement is impacted by these very enforcement authorities being compromised by the same means, which they are to investigate and prevent. This problem is further compounded by inordinate delays in our justice dispensation mechanism which is widely taken advantage of, and the legislative hindrance that the Prevention of Corruption Act, 1988 poses in the form of requiring ‘sanction to prosecute’ high ranking officials.

Enforcement is not ideal but it is yet to be devoid of not having a deterrence impact all together. The Indian legal system is provisionally sound to deal with corruption when the need arises and the question for companies really is, whether in the cross winds of media trials, whistleblowers and enhanced public scrutiny – they would like to the object of this system working?

As for preventing foreign bribery – as of date it does not constitute an offence in India. As India has signed and ratified the UN Convention Against Corruption, in compliance of which a bill is pending in the Indian parliament since 2011 namely the Prevention of Bribery of Foreign Public Officials and Officials of Public International Organizations Bill, which seeks to criminalize foreign bribery.

RB: Sherbir, so here is where you can really provide some assistance to those who look to the Indian market for growth. What advice would you give them in terms of how to conduct business with respect to corruption risk? I ask this in two parts, first, what do they need to do before entering the market to steer clear of corruption, and for those already in the market, what do they need to do to maintain anti-bribery ethics and compliance?

SP: The corruption risk in India is very real and apparent, and businesses must attempt to constructively address this risk and not “just go with the flow”. I say this as many a times I have seen foreign companies resign themselves to the fact that bribery is a cost that they have to incorporate into their India operation, thereby making no genuine efforts to prevent it. This resignation at times accrues greater liability for business as it breeds a culture of using bribes as the easier way out. Let me emphatically state that business in India is possible without bribery. Easy – no, possible – yes; and this gap can be bridged by a determined organization.

Enforcement of laws preventing foreign bribery have helped create a certain degree of universality in compliance policy, the devil however is with the on ground challenge. Addressing the bribery issue outside a mere policy framework mandates that an anti corruption strategy for India focuses on ‘knowing the challenge and preparing for it’ and ‘avoiding avenues of bribery’.

Knowing the challenge and preparing for it: The bribery challenge in India is one that in the course of business you are likely to regularly encounter as opposed to as an exception. Therefore, understanding the challenge in the Indian context and accordingly responding to it is imperative.

  • Firstly, there are no good bribes or bad bribes. Once a reputation as a bribe payer is established, my experience has been that the company is regularly flocked to by public servants from diverse backgrounds demanding bribes for simple tasks or at times for no tasks at all, but just in case there is a future task. Word spreads fast and the scale of bribery multiples even faster, with the company then being required to provide lavish gifts during festivals, an increase in the bribe amount every year or even a bonus bribe for loyalty.

Companies which choose to believe that small bribes or facilitation money thus are acceptable should take a step back to determine its impact, and should also view it in the context of the organizational culture they are building. While operating in a country which has a cultural disposition to bribery due to the unfortunate ground reality, you would not want that culture to be given sanction in the organization as well.

  • Secondly, compliance policies and procedures need to address elements of Indian law and ground realties specifically. For example, under Indian law specific threshold limits are prescribed in Indian Rupees for the gifts, entertainment and hospitality that public servants may receive. Now if a company’s gift policy is listed in USD terms there could be a high possibility of violation due to currency rate fluctuations inadvertently if not more blatantly by getting the value wrong all together. Another example is third party agent due diligence forms which use the word ‘company’ for the third party; while majority of third parties / agents are organized as sole proprietorships and partnerships – thereby allowing them to make incorrect disclosure to the foreign company.

These are small examples of minor mistakes having greater repercussions for businesses operating in India, hence it being important to localize compliance.

  • Thirdly, is creating a response framework to when there is a bribery log jam. Merely communicating to employees to refuse bribe payments, does not necessarily solve the problem at hand. There is no easy way to address this issue and it varies from case to case, but companies – among others do have available to them the option of reporting the matter to the Anti Corruption Bureau of the concerned state or where they find an arbitrary decision being given by a public servant due to bribery or the lack thereof approach the concerned High Court via writ jurisdiction. Pros and cons aside, it is helpful to know and communicate to the rank and file, that options do exist.

Avoiding avenues of bribery: Businesses should plan out their operations by determining where and how they can limit interaction with government entities. This is no easy exercise and would not have a one size fits all, but is an effort worth undertaking. For example, if a procedure can be e-filed versus filing it physically at a government department; obtaining information through the Right to Information Act, 2005 versus exposure to bribery by sending an employee to a government department; using the right to service legislation / citizens charter in states where applicable versus engaging third parties who are likely to add to a company’s exposure; single window clearance while setting up operations in a special economic zone versus having to deal with a multitude of government departments and agencies. While these examples do not guarantee bribery free business, they considerably reduce the odds of it.

An exercise in bribery avoidance, will also help streamline interaction with government servants where it is unavoidable, thereby allowing them to also understand the company’s firm stand on business ethics. Companies would thus benefit by incorporating into their strategy creative mechanisms of avoiding bribery at an operational level as opposed to a mere policy framework of what to do when the big question is asked.

RB: From my own experience with Indian procurement, and let me share for those who have not experienced this first hand, it is a very complicated process. The Indian rules and regulations governing procurement on a National, Regional and Local level are somewhere between intricate and entirely confusing. The paperwork, for lack of a better word, is massive, and as stated, quite often puzzling. Sherbir, as we all know, this leads to great dependence on third parties to sort out such regulations, and also presents great peril with respect to requests for small bribes to “move things along.” So, what responsibility does India have to make this process as structurally sound as possible, as to reduce the risks for companies outside India to enter the market in a way which is fair and transparent? Also, my reflection here is from my experience up to 2009, so since then, do you think there has been progress?

SP: Richard, the red tape, paperwork and plethora of complex rules and regulations is still very much a reality when it comes to public procurement in India. Incidentally, India’s dismal ranking in the World Bank’s Ease of Doing Business Report took a hit by another two places in 2015. The responsibility for this squarely rests on India if it seeks to continue to attract foreign investment and remain an investment viable economy. The argument for us is not just social and moral, but economic. A major push towards e-governance and consolidating regulatory procedures is necessary and the Finance Minister – Mr Arun Jaitley, while introducing India’s budget on 28th February 2015 has made strong references to help ease doing business in India. But only time will as to how many of these initiatives actually are implemented effectively.

From an on ground perspective, when it comes to public procurement the use of mandatory integrity pacts has helped level the playing field slightly as action for breach of the pact has been swift. The Integrity Pact lays down mandatory no bribe giving / no bribe accepting provisions, the violation of which may result in blacklisting, forfeiture of bid deposits and bank guarantees among others. In January 2014 AgustaWestland had a Euro 550 Million contract with the Ministry of Defence cancelled for violation of the integrity pact, and earlier in 2012 six companies were blacklisted for 10 years in India by the very same Ministry.

Also pending in our Parliament since 2012 is the Public Procurement Bill, 2012 which endeavors to bring about reform in public procurement by mandating publication of all procurement related information at a central portal, establishment of a bidder grievance committee and establishing open competitive bidding as the preferred procurement method.

RB: Thank you for your time today, is there anything else you would like to add?

SP: Thank you for the opportunity to address your readers today Richard, it has truly been an honour.

On a parting note I would like to reiterate that business is no longer as usual in India, and companies that do not respond to these changing times are likely to be impacted adversely. With all our shortcomings and challenges, we remain a rule of law upholding democracy and if one is on the wrong side of the anti bribery law when it is being upheld, the consequences will follow.

Indian employees are also growing increasingly aware of laws that foreign companies are bound by internationally, not just in terms of foreign bribery prevention but whistle-blowing also. Questionable practices are therefore likely to face greater resistance from the workforce as well. The risk of disclosure of misconduct and scrutiny into company actions, stands considerably higher than what it was in the last decade – to which the compliance function must respond. The compliance function thus, needs to depart from a ‘tick the box’ liability reduction model to one that builds a dynamic and determined culture of integrity.

As a footnote Sherbir can be reached via e-mail at [email protected] on Linkedin here and Twitter here. 

Written by:

Richard Bistrong,  Anti-Bribery Consultant & Speaker

Richard Bistrong, Anti-Bribery Consultant & Speaker 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.