Conducting Anti-Corruption Due Diligence on Third Parties9月 29, 2013 The FCPA Report
Nicole Di Schino of The FCPA Report interviews Nardello & Co. for their series, “Conducting Anti-corruption Due Diligence on Third Parties”. The Nardello team discusses some of the risks of retaining third parties and the most effective ways of conducting due diligence to alleviate these risks.
Nicholas Peck gives examples of third parties on whom due diligence should be directed: “Companies should focus on whether an agent has other government contracts, for example whether it needs licenses from the government to operate.” He goes on to say, “Companies often don’t think about the agents who are already in place. They think, ‘I’ve been working with that guy for ten years,’ and don’t think to do a due diligence investigation.”
Dan Nardello stresses the importance of having set due diligence policies and procedures. When asked if he thought these should be written, he replies, “Nowadays they have to be written because a corporation has to be able to prove that they exist. Additionally, if a company is serious about due diligence, particularly big multinational corporations, the policies have to be written, they have to be communicated to employees, and people have to be able to consult them.”続きを読む