Page 45 - CCCA 270450 Magazine_Fall 2017_for web

{ stRategic ManageMent }

a physical inspection of a contractor’s Activities subject to vetting typically a donation to a charitable organization
premises and equipment, or due diligence include gift giving, provision of hospital- to whom the company has never given
on a request for payment by a third party ity and transportation, political contribu- before, in a country with a high corrup-
in an account outside of its jurisdiction. tions, charitable donations and sponsor- tion index where the company is pursu-
The level of control and vetting im- ship, hiring of employees with ties to the ing business may require a review by the
posed on permissible activities should be government or government offcials, re- Legal Department.
based on not only the risk of corruption tention of commercial intermediaries and The output of this activity should be a
involved in each activity but also the fre- consultant, retention of custom brokers detailed list of activities, classifed by risk
quency of the activity and the complex- and freight forwarders, acquisition of per- level, with a description of the associated
ity of the risk analysis associated with the mits, exports and imports, lobbying, and vetting. This list is the backbone of the in-
activity. Because it is diffcult for organi- selection of high risk suppliers. ternal controls program.
zations to perform processes associated A single type of activity can require The fnal instalment of this four-part
with activities occurring infrequently eff- different levels of vetting, depending on series will review how to implement these
ciently and reliably, consideration should the risk it presents. For instance, a pro- internal controls effectively and how to
be given to centralizing the vetting of posed modest charitable contribution by design the detective controls that will al-
infrequent activities and assigning it to a company to a reputable and well estab- low counsel to measure the health and ef-
specialized resources. Similarly, the vet- lished charitable organization not affli- fcacy of your compliance program. ❚
ting of activities requiring deeper or more ated with government offcials, based in
complex analysis should rest with more a country where the company has an es-
experienced, more specialized resources. tablishment and to whom the company Isabelle Pierre is Deputy General Counsel at Gen-
eral Dynamics Land Systems. She is currently on
Routine or lower risk activities can often has made payments in the past may re- maternity leave.
quire a simple due diligence. By contrast,
be delegated to working-level employees.
“ Te design of a good compliance program starts

with a self-assessment of the risk associated
”
with an organization’s activities, followed by the
design of required preventative controls.

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