The FCPA Blog | By: John Bray | June 28, 2017 at 8:18AM:
How far is it feasible to apply a global compliance policy in widely differing regional markets? And to what extent should there be local policy exceptions?
In Control Risks’ 2017 International Business Attitudes to Compliance survey, a majority of respondents (55 percent) say that their global compliance policy applies worldwide, without any local exceptions. Just over half of U.S. companies surveyed (51 percent) take this stance, compared with 56 percent from Germany, 57 percent from Brazil, 63 percent from the UK, and 67 percent from France.
However, a substantial minority of companies said that their company policies did have local exceptions in three key areas. These are “gift-giving,” chosen by 40 percent of respondents. This is followed by “permitted interactions with government employees or agents” (30 percent), and “the use of facilitation payments” (20 percent).
The survey does not go into detail on the nature of these exceptions. However, in many cases the purpose of local variations may be to reinforce the company’s international position rather than to relax it. As one respondent puts it, “Exceptions are usually used to make the controls tighter than the global ones used by our parent company.”
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