Overview
Steptoe partner Iris Bennett was quoted by Anti-Corruption Report in an article titled "Southern Glazer’s Settlement Highlights How Compliance Can Mitigate the Risks of Domestic and Commercial Bribery." The article discusses a recent corporate Non-Prosecution Agreement with the US Department of Justice in a commercial bribery matter, and highlights the critical role of tailored and robust remediation both to address the underlying reasons that misconduct occurred and was allowed to persist, and to achieve an acceptable settlement with the government. The settlement underscores the rigorous expectations applied by the Department for robust compliance functions, leadership accountability, third-party oversight, and ethical culture, all of which are relevant to mitigating both bribery and many other types of compliance risks. Regarding the company’s promotion of its General Counsel to EVP Chief Legal and Compliance Officer, which was cited as a positive step by DOJ, Iris observed that "when the legal and compliance roles are combined and held by one individual, it is key that that person is still accountable to the board and its audit, governance and compliance committees, and that the board and committees are closely monitoring for situations in which the compliance role is in tension with the legal role."
Read more at Anti-Corruption Report. [subscription required]
