Anti-corruption

What is the issue: Legal and compliance risks regarding corruption are higher than ever before. Compliance and ethics programs to help organizations manage legal risks can no longer be considered optional. At the same time, government standards for these programs have become increasingly specific. In short, promoting and maintaining an ethical corporate culture is essential for a company’s survival and success.

No area is safe: prosecutors all over the world aggressively attack corporate crime and fines keep getting bigger. The U.S. Dodd-Frank Act has provided employees with an incentive to report concerns to the U.S. government – rather than to their employers – which enhances the need for robust compliance programs.

“Effective compliance programs are tailored to the organization’s specific business and to risks associated with that business. They are dynamic and evolve as the business and markets change.”
A Resource Guide to the U.S. Foreign Corrupt Practices Act DOJ/SEC

New technology is emerging to help prosecutors discover violations.

Best practices in compliance are raising the bar of government expectations. They provide ways for every compliance officer to do more with less and for every compliance program to function more effectively.

How we can assist:
Givon Advisors has developed, implemented, and reviewed anti-bribery anti-corruption programs for large and smaller organizations. They include a broad range of specific actions:

  • conducting risk assessments,
  • drafting of policies, procedures and communications,
  • training all levels of employees, officers and directors,
  • undertaking compliance audits and implementing corrective actions, as required.

Given that liability for corrupt activities often arises in connection with actions taken by third parties rather than directly by the organization itself, choosing the right third-party supplier/partner can make the difference between having a significant asset or a major liability. We work with you in developing:

  • anti-corruption related agreements for joint ventures, agents, consultants, key vendors, and other business relationships,
  • anti-corruption training modules for agents, consultants, and third-party intermediaries,
  • a sustainable program to select third parties to make sure that they not only meet price, quality and delivery requirements but also comply with regulatory and anti-bribery standards. We have conducted many reviews of prospective agents, consultants, and joint venture partners in Europe, the Middle East, South America, North America, and the Asia-Pacific region.

In the area of mergers and acquisitions, we assist with anti-corruption due diligence into foreign acquisition targets with substantial operations in developing countries. Based on results of our due diligence, we develop anti-corruption compliance programs for merged entities, including the drafting of anti-corruption policies and training materials. We assist clients with in­-person training prior to closing.