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June 2015

Compendium Roundup

A variety of anti-bribery enforcement activity occurred this month. Gold Fields Ltd. announced that the U.S. Securities and Exchange Commission ("SEC") had closed its investigation into the company and would not recommend an enforcement action for possible violations of U.S. Foreign Corrupt Practices Act ("FCPA"). The SEC had been investigating allegations that the company had provided a share allocation to an official in South Africa to ensure a Black Economic Empowerment transaction concerning the company's South Deep mine went forward. Net 1 UEPS Technologies announced that the SEC had closed its investigation into the company and would not recommend an enforcement action against the company for possible violations of the FCPA. The investigations into Net 1 by the SEC and the U.S. Department of Justice ("DOJ") were focused on payments the company allegedly made to South African officials to obtain a contract with the South African Social Security Agency. The DOJ investigation is still ongoing.

Read more on the TRACEblog>>>

Featured Resource: TRACEsort

TRACEsort offers companies an efficient, cost-effective way to collect and assess third party risk information, manage due diligence reviews, upload supporting documentation and record a definitive on-boarding decision for any number of third parties. As a member benefit, TRACE Corporate Members pay a discounted hosting fee of just $3000 to implement and deploy this third party risk management tool. Recent updates to the TRACEsort platform include:

The ability to have "split" questionnaires, allowing TRACEsort users to combine responses from their third parties with internal information to generate the overall risk score.
A messaging system that allows TRACEsort users to send links to questionnaires to their third parties, their colleagues, or both when they are inputting third party information into the system.

For more information on TRACEsort or to schedule a demo, please click here.

Publications

4 strategies to overcome the grey areas in your compliance program and avoid corruption

18 June 2015

Alexandra Wrage, Trade Ready

2014 Global Enforcement Report (GER)

June 2015, TRACE

Benchmarking Survey: Third Party Commission Rates (Asia)

The Asia segment of the TRACE Commission Benchmarking Project survey includes China, India, Indonesia, South Korea and Kazakhstan. This project will provide data on the average commission rates paid to third parties on a country-specific basis for business-to-government deals based on four deal sizes. Business-to-government deals are defined as contracts between companies and regional, municipal or federal governing bodies. Anti-trust counsel has reviewed the survey questions, and we ask that you use only commission rates paid in Q4 2014 or prior when answering the questions.

Unlike other benchmarking project, the results of the Commission Benchmarking are not available EXCEPT to those companies that participate. To receive a copy of the survey results, please submit one response per company by July 24, 2015. Click here to participate.

*If you participated in any of the previous segments and have not yet received a copy of the final results, please write to DRowlandLindahl@TRACEinternational.org.

Online Training: New Modules

As we look to expand our online training options, we would like to provide you with the opportunity to select future training module topics. We invite you to participate in a one question survey available here.

Current Modules Include:

Anti-Bribery Training

Conflicts of Interest

Avoiding Trafficked Labor

Coming Soon:

NEW Anti-Bribery Training

Conflict Minerals

To learn more about online training options, please write to training@TRACEinternational.org.

TASA: TRACE Anti-Bribery Specialist Accreditation

TASA: TRACE Anti-Bribery Specialist Accreditation� webinars are now available to TRACE members at no additional charge.

Register for a live webinar or view any recorded webinar in the TRACE Resource Center. For more information, contact info@theTASA.org.

Recently Recorded Webinars:

Anti-Bribery Compliance Challenges in the Middle East
Offsets, Charitable Donations, and Other Foreign Government Requests: What Are the Risks?
Conducting an Effective Anti-Bribery Risk Assessment

Interested in taking the TASA accreditation exam? Enroll in TASA today and become TASA accredited by the end of 2015. To inquire about discounts and credits, write to info@thetasa.org.

Advanced Roundtable Discussions

These invitation-only, advanced sessions provide senior-level compliance professionals with the opportunity to share best practices and discuss emerging trends. Fall 2015 roundtable locations are listed below. To request an invitation, please write to workshop@TRACEinternational.org. Space is limited and is first come, first served.

London (as part of London Int'l Shipping Week)
Click here to view the agenda.
8 September

Copenhagen (as part of Danish Maritime Days)
Click here to view the agenda.
8 October

Paris
Click here to view the agenda.
16 October

Havana
Agenda under development.
3 November

Regional Anti-Bribery Workshops

TRACE workshops provide practical, in-depth anti-bribery training for your global employees and intermediaries. These events feature TRACE representatives, compliance and business executives and TRACE Partner Firms. Register today for our fall 2015 locations.

Manila Click here to view agenda-at-a-glance.	9 September
Mexico City	10 November

Global Anti-Bribery In-House Network (GAIN)

This high-level event provides TRACE Member Companies with the opportunity to share best practices and learn first-hand from TRACE Partner Law Firms and one another about corruption risks and enforcement trends around the world. Register now for this highly anticipated event.

London
Venue: Mandarin Oriental, Hyde Park
View the agenda-at-a-glance.

13-14 October

Partner Events

JULY

Global Anti-corruption Regulatory & Enforcement Update

Hosted by: ACI

July 20

Washington, DC

6th Global Forum on Anti-Corruption and Compliance in High Risk Markets

Hosted by: ACI

July 21

Washington, DC

For a complete list of upcoming events, visit the Upcoming Events Calendar on our website.

International Regulatory Updates

Canada

Miller Thomson LLP

Canada recently enacted new procurement rules which provide for ten year debarment following a conviction or guilty plea with a conditional or absolute discharge for any number of primarily corruption-based Canadian or similar foreign offences. Following a public outcry, the Government indicated, that it would introduce a new integrity regime for procurement that is "consistent with best practices in Canada and abroad."

Georgia

BGI Advisory Services Georgia

Recent amendments to the Law on Conflict of Interest and Corruption in Public Sector in Georgia define whistleblowing as reporting by public servants or former public servants to relevant public institution, investigator, prosecutor and/or public defender of Georgia regarding violations of the laws of Georgia or norms of Code of Ethics by a public servant when such violations have resulted in or may result in damages to public interests or reputation of respective public institution. The statutory authority provides protections of the whistleblowers, which, inter alia, include prohibition of disclosure of the whistleblower's name unless such disclosure is expressly consented by the whistleblower in writing.

New Partner Firm - South Sudan

Juba Associated Advocates