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
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
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