In today’s edition of Daily Compliance News:
Tag: Supply Chain
One of the areas many companies do not focus on enough is possible corruption in their supply chain for goods and services provided on a company’s behalf. The FCPA risks can be just as great through those entry points as it can be through the sales side of an organization. You need to know who your company is doing business with through this channel as much as you need to know your agents seeking business opportunities on your behalf. Most companies have exponentially more vendors than sales agents, so this task may seem daunting. However, a well thought out plan to risk rank your company’s third-parties on the supply chain side can go a long way towards ameliorating this issue. The key is to set reasonable parameters and then management those third-parties which present true corruption risk to your organization.
This determination of the level of due diligence and categorization of a supplier should depend on a variety of factors, including, such factors as whether the supplier is (1) located, or will operate, in a high risk country; (2) associated, or recommended or required by, a government official; (3) currently under corruption investigation, or has been recently convicted of any form of corruption; (4) a multinational publicly traded corporation with a recognized exemplary system of compliance and internal controls; or (5) a provider of widely available services and products that are not industry specific. You should note that any supplier, which has foreign government touch points, should move up into a higher level of scrutiny.
My suggestion is that you create a three-tiered risk matrix consisting of (1) high-risk suppliers, (2) low-risk suppliers, and (3) minimal-risk suppliers. Below this final category is another category for providers of goods which are commonly available and pose almost no corruption risk.
You need to risk rank the third-parties which your supply chain might engage with for FCPA exposure. It should be based on your company’s experience and risk going forward. As with all other third-party risk management issues, you must “Document, Document, and Document”.
Three key takeaways:
- Risk rank your supply chain based on well-conceived strata.
- Consider not only the compliance risk but also your business risk.
- Only manage those suppliers which present a corruption risk.
Welcome to the newest addition to the Compliance Podcast Network, Compliance and Coronavirus. As the Voice of Compliance, I wanted to start a podcast which will help to bring both clarity and sanity to the compliance practitioner and compliance profession during this worldwide health and healthcare crisis. In this episode, I am joined by Matt Whitaker, Vice President, Growth at Assent Compliance. We visit Assent’s COVID-19 Supply Chain Impact Map, and how it assists companies, the data that Assent Compliance is seeing from it and where Supply Chains will go in the new normal of Covid-19.
You can use the Assent Compliance Covid-19 Supply Chain Impact Map to visualize and assess the impact of the Coronavirus on your supply chain, by clicking here. The COVID-19 Supply Chain Impact Map is a free tool that overlays COVID-19 data onto supply chain maps, providing visibility into its impact on key suppliers and shipping hubs. This enhanced transparency provides companies with the information required to make informed business decisions, and adapt to supply chain and market access disruptions.
In this five-part podcast series, sponsored by Assent Compliance Inc. (Assent), I have explored the market impacts of emerging regulations on supply chain compliance and the supply chain professional. During the course of this series, I visit with several members of the Assent team to introduce the topic, look at Human Trafficking and Slavery (HTS), supply chain risk management programs, CSR value propositions, the current state of responsible mineral sourcing and where all of this is headed. In this fifth and concluding episode, I visit with Jonathan Hughes, Director, Strategic Relationships at Assent Compliance. We considered how the market impacts are driving the need for more technology-based solutions for supply chain management.You can check out more about Assent Compliance Inc. at their website, by clicking here.
In this five-part podcast series, sponsored by Assent Compliance Inc. (Assent), I explore market impacts of emerging regulations on supply chain compliance and the supply chain professional. During the course of this series, I visit with several members of the Assent team to introduce the topic, look at Human Trafficking and Slavery (HTS), supply chain risk management programs, CSR value propositions, the current state of responsible mineral sourcing and where all of this is headed. In this fourth episode, I visit with Jared Connors, subject matter expert for Assent Compliance on Corporate Social Responsibility (CSR) on the current state of conflict minerals/responsible minerals. Join us tomorrow where we wrap us this series on emerging regulatory areas in a conversation with Jonathan Hughes. You can check out more about Assent Compliance Inc. at their website, by clicking here.
In this five-part podcast series, sponsored by Assent Compliance Inc. (Assent), I explore market impacts of emerging regulations on supply chain compliance and the supply chain professional. During the course of this series, I visit with several members of the Assent team to introduce the topic, look at Human Trafficking and Slavery (HTS), supply chain risk management programs, Corporate Social Responsibility (CSR) value propositions, the current state of responsible mineral sourcing and where all of this is headed. In this episode, I visit with Sarah Carpenter, Manager, Business and Human Rights for Assent Compliance on the value proposition of CSR for corporations. Join us tomorrow where we consider the current state of conflict minerals/responsible minerals with Jared Connors? You can check out more about Assent Compliance Inc. at their website, by clicking here.
In this five-part podcast series, sponsored by Assent Compliance Inc. (Assent), I explore market impacts of emerging regulations on supply chain compliance and the supply chain professional. During the course of this series, I visit with several members of the Assent team to introduce the topic, look at Human Trafficking and Slavery (HTS), supply chain risk management programs, CSR value propositions, the current state of responsible mineral sourcing and where all of this is headed. In this second episode, I visit with Jared Connors, subject matter expert for Assent Compliance on Corporate Social Responsibility (CSR) on how to institute a broader supply chain risk management program. Join us tomorrow where we ask, ‘what’s your CSR value proposition’? You can check out more about Assent Compliance Inc. at their website, by clicking here.
