Question
You are the Chief Compliance Officer at a major American retailer where there has been a violation of the FCPA. Using what you have learned
You are the Chief Compliance Officer at a major American retailer where there has been a violation of the FCPA. Using what you have learned about anti-corruption compliance programs, need a memo describing ways to implement policies or practices to adjust your company's compliance program.
Grading Criteria Overview
One of your peers will review and score your work using the following criteria in their assessment of your submission:
The memo describes two policies or practices that would help prevent employees from engaging in corrupt behavior
The memo describe two different policies or practices that would help prevent third party vendors from engaging in corrupt behavior
You are the Chief Compliance Officer at a major American retailer. Recently, a senior manager at your company violated the FCPA by bribing Chinese officials in exchange for customs and shipping benefits. There are whispers that some of your company's third party vendors are engaging in corrupt behavior as well, and the U.S. government is investigating. The CEO has asked you how the company should alter its compliance program given these issues.
Need a memo to the CEO in which you:
1)Describe two policies or practices that the company should have in place to prevent employees from engaging in corrupt behavior.
2)Describe two policies or practices that the company should have in place to prevent third party vendors from engaging in corrupt behavior. They should be different from those discussed in Part 1.
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