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Complying with anti-corruption regulations has always been a challenge for large multinational enterprises conducting business in many different markets. Over the past 15 years, enforcement of the U.S. Foreign Corrupt Practices Act (FCPA) has increased dramatically, and anti-corruption efforts outside the U.S. have intensified as well. This case study examines an approach Teva Pharmaceutical Industries developed with its consulting partner to identify and manage potential third-party risks to FCPA compliance across its global operations.
Teva needed a way to identify which of its more than 500,000 vendors and customers could create possible FCPA risk — including agents, consultants, distributors, suppliers, vendors, and any other entity or individual facilitating or involved in any transaction with government officials or agencies — and ensure that appropriate due diligence was performed before they were hired or paid.
But Teva’s aspirations went beyond meeting legal requirements. Its officially stated goal was to “build the best and most respected global compliance program in the industry — a program that works in partnership with the business to prevent issues.” That meant business sponsors needed to understand that compliance was a part of their responsibility and that they would be held accountable for their decisions. Accordingly, the compliance department needed to provide the business with the right tools, resources, policies, and training to facilitate the right decisions. In third-party due diligence, specifically, the goal was to transform Teva’s program into a system that other companies would strive to replicate.
To address these challenges, Teva hired a consultant that had both innovative ideas and was willing to partner to develop such a system. Download the full case study report to learn how Teva and its partner worked together to develop a system that will allow the company to meet its goal of building the best global compliance system in its industry.