Anti-corruption has become a major global initiative, as evidenced by efforts of organizations such as the World Trade Organization (WTO), European Union, Organization of American States, Association of Southeast Asian Nations, Caribbean Community and the African Union, among others, to require their members to address it. Still, it is naïve to expect that legislators, regulators, international trade organizations and other parties can eradicate customs and behaviors that have evolved over many centuries. This board of directors and management questionnaire focuses on corruption risk, the Foreign Corrupt Practices Act (FCPA) and other key considerations.
This sample includes questions, such as: Does it make more sense to cease engaging in high-risk business in the country, or to investigate and correct any problems, or to determine with certainty that there are no problems? Are the company’s anti-corruption controls and compliance program within its financial and operational processes actively monitored by management to identify potential red flags that warrant attention? What is the cultural, political and regulatory environment of the countries in which you conduct business? Is your joint venture partner or representative related to, or recommended by, an official of the potential governmental customer? What types of leasing agreements has your organization arranged in foreign countries?