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This month's dilemma.

Document Cited in Related
Vincent
AuthorBarman, Tanya
PositionHot potato

I'm a LIMA member working in internal audit for a company with overseas subsidiaries. I'm concerned that one of these subsidiaries makes purchases from a local firm that is known to be involved with corruption (bribery and payments off record etc). I do believe, due to systems we have in place, that our particular contract is run well, but I am not confident that this is the case in relation to their activities with other clients.

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Our response:

With the global jurisdiction of both the US's Foreign Corrupt Practices Act and the UK Bribery Act, any association with an organisation known for corrupt practices should be carefully considered. It seems that you have undertaken due diligence in respect of the local firm and it appears to pose both a reputational and commercial risk. Should an instance of bribery occur in relation to your business it may have...

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