Global Know Your Supplier Compliance for Fortune 250 Retailer


When a Fortune 250 retailer faced US Department of Justice monitoring over anti-corruption rules, Integreon helped the company complete a detailed compliance survey of approximately 2,000 high-risk suppliers, in 35 languages, across the globe. Integreon drew on multilingual Associates in the US and UK to complete the survey on-time and on-budget.


In May 2013, Integreon was engaged by a major multi-national retailer to assist in a highly sensitive global compliance initiative relating to anti-corruption legislation, specifically the US Foreign Corrupt Practices Act and comparable local laws, e.g. the UK Bribery Act. Headquartered in the US, the client is a true multi-national, with customers and suppliers across the globe.

Faced with the likelihood of having a Department of Justice monitor imposed on them, the client needed to undertake a due diligence "Know your Supplier" overview of its global supplier network to ensure compliance with the aforementioned anti-corruption rules. This overview needed to be completed within six months. With support and supervision of its outside counsel, a top five global law firm, the client categorized its network of 80,000 suppliers around the world into low-, medium-, or high-risk business relationships. Integreon was engaged to reach out to the approximately 2,000 high-risk suppliers and ensure that each one completed a Know your Supplier due diligence questionnaire.


The 23-page Know Your Supplier questionnaires addressed each supplier's compliance with the Foreign Corrupt Practices Act, the UK Bribery Act and local anti-corruption laws relevant to the jurisdiction in which the supplier was located. The questionnaire was customizable to apply to any and all types of suppliers, ranging from global multi-nationals to local traders. The questionnaire requested that suppliers provide information pertaining to their financial and business relationships with the clients, their ownership and operating structure, and whether the company or any of its directors/major shareholders had ever been investigated in connection with breaches of anticorruption legislation.

Prior to the project launch, Integreon collaborated with the client and outside counsel on the format and language of the questionnaire. Utilizing its pool of multi-lingual lawyer resources, Integreon undertook a sense check of the foreign language questionnaires. Integreon's resources also assisted in the customization of the questionnaire to reflect different countries' approaches to answering certain questions....


In a highly sensitive situation, where sufficiently qualified internal resources did not exist and the cost of outside counsel was prohibitive, Integreon's multishore, multi-lingual delivery ensured the project was completed cost effectively, efficiently and on-time.

The dual-shore delivery model and flexibility of Integreon's resources facilitated seamless communication with the client's global network of suppliers. Integreon also achieved invaluable synergy gains from working across two locations. This approach encouraged the sharing of know-how and best practices. Perhaps most importantly, the high quality of Integreon's legally qualified multi-lingual resources assured that what at times could be difficult interactions with suppliers across the globe were handled tactfully and with the utmost professionalism.