Compliance & Ethics Programs

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Third-party-related Compliance & Ethics Needs

It is becoming increasingly common for companies to make certain components of their Compliance & Ethics programs applicable to some categories of non–employees, such as suppliers, distributors, agents, contractors, temporary workers, joint venture partners and others. The attorneys of Kaplan & Walker LLP have assisted many companies in developing or reviewing Compliance & Ethics controls applicable to non–employees, such as supplier codes of conduct, anti–bribery policies applicable to third parties, anti-corruption training for agents and distributors, Compliance & Ethics requirements for joint venture partners and Compliance & Ethics related due diligence check lists for use in retaining third parties or acquiring other companies.

Additionally, Rebecca Walker co–authored a Conference Board research report entitled Third Party Ethics Requirements, which examines the responses of 169 companies to a large number of detailed questions regarding those compliance requirements and standards that companies extend to third parties, including: (1) which third parties are subject to their companies’ compliance program requirements or expectations; (2) which types of requirements or expectations are extended to various categories of third parties; (3) what, if any, enforcement mechanisms are utilized by organizations when third parties fail to comply with applicable requirements; and (4) what new strategy choices or challenges these outcomes raise for companies. Rebecca Walker also authored a survey regarding third party codes of conduct, which was disseminated by the Society of Corporate Compliance and Ethics.