Building ABC due diligence for FMCG multinational

Anti-corruption due diligence has proved to be the hardest anti-bribery practice for companies to implement. Based on our findings from over 40 assessments, the GoodCorporation White Paper Combating Corruption: are businesses doing enough? revealed that almost two thirds of the due diligence procedures assessed were graded as inadequate.

GoodCorporation helped one of its FMCG clients to develop a robust anti-bribery due diligence process. The challenge for many complex businesses is processing and prioritising large numbers of third parties. Using GoodCorporation’s due diligence methodology, our client was able to:

  • Identify and prioritise those third parties that require due diligence
  • Assess the level of risk posed by the third party and the scale of due diligence required
  • Understand the nature of the risk and the mitigation measures needed
  • Identify whether or not the third party could still be used
  • Document the relationship and the agreed terms
  • Establish a monitoring system to manage any risk moving forward.

These steps were used to design and develop a tailor-made due diligence system which was then tested in two high-risk African markets. The process was then refined and rolled-out worldwide.

Management must empower those conducting due diligence to act on the information received and support those difficult decisions that may need to be made as a result.

Anne-Fleur Goedebuure

GoodCorporation consultant commenting on the FCPA Blog

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