Ignorance is not Bliss with Foreign Corrupt Practices Act Compliance

Cathy Connally Blog, Corporate Governance, Emerging Markets, Financial Compliance 0 Comments

Discussion of Foreign Corrupt Practices Act & Ignorance from Sam Carr, Managing Partner of Carrtegra, LLC.

“Thanks Sam for sharing this presentation and the blog entry.” You make some great points and I totally agree that we get what we tolerate in business.

Standards for honesty should not be flexible.

I found the feedback from the attorneys very interesting. I wonder if that would hold up under investigation. The lawyers I work with would probably come down more on your side with defense from a process that is preventative can go a long way to show that management was not just trying to tick a box but really trying to provide reasonable assurance that attempts were made to prevent or detect fraud. And when detected, actions would be taken.

I have worked all over the world including some of the “red” countries highlighted in your slides. But always if there was ever a smell of corruption or bribery in a possible deal, we said no to bribery.

Sometimes we win because we are the best and people respect you for having standards. In many cases, our brand equity improved because companies knew we would not be persuaded to change our values. They wanted to be associated with our company and have the “halo” of good governance. In some cases, we lost the business. The best decisions I have made over the years have been the deals I did not take.

As business leaders, we must do what is right and listen to wise counsel but not be too swayed by fears of litigation. Otherwise, what compass do we have? If you can be bought, generally people will know.

Leave a Reply