Problem: The police descended on the headquarters of a Fortune 50 firm and searched the premises. The firm, which has business interests in more than 190 countries, learned that the police and prosecutor were investigating multiple allegations of violations of the Foreign Corrupt Practices Act. The raid was followed by significant press coverage and further searches and seizures.
Action: Within a few weeks of the initial raid, the company retained Michael Hershman and the Fairfax Group as the independent compliance advisor to the board of directors. We were asked to thoroughly examine and restructure the company’s compliance and governance procedures.
Result: Within eight months, the company acted on more than 40 recommendations to revise its business legal and compliance structure. It is now recognized as a model for corporate compliance and citizenship.