Who we worked with
A major US footwear and apparel leader with a 150-country reach.
What the company needed
A framework for assessing and improving controls and compliance with anti-corruption laws throughout its widespread global enterprise.
How we helped
We conducted an in-depth risk assessment and due-diligence screening review of vendors in high-risk countries, then built a robust compliance and governance mechanism based on what we learned.
What the company got
More thorough compliance with the Foreign Corrupt Practices Act (FCPA) and other anti-corruption regulations.
A leading American multinational that designs, manufactures, and retails footwear and sports apparel around the globe faced a real risk. It was hard to make sure it was complying with all the anti-bribery laws in the 150 companies in which it operates. Genpact conducted a thorough screening of vendors in high-risk countries, performed risk assessments to identify control gaps in key high-risk processes, and designed a comprehensive framework for anti-corruption monitoring to drive tighter compliance.
Challenge
Develop a vigorous anti-corruption framework that is consistent worldwide
Working in more than 150 countries exposed the company to a significant risk of violating various anticorruption laws such as the Foreign Corrupt Practices Act (FCPA). Compliance was complicated by:
- No mechanism for screening new vendors or evaluating the client’s 120,000 existing vendors for FCPA compliance
- Poor risk assessments to identify and mitigate anti-corruption across critical processes
- Inadequate monitoring of high-risk spends, travel and entertainment (T&E) expenses, and promotional products
Solution
Scour the existing risk management system. Eliminate questionable vendors. Close gaps. Apply analytics to find red flags
After we did a thorough risk assessment in seven high-risk countries, we created a robust regulatory compliance and governance framework. We used our relationship with Lexis-Nexis to design and build a more comprehensive vendor screening process and compliance framework with built-in data analytics that includes:
Vendor screening process
- We screened a database of about 120,000 vendors in high-risk territories to identify and eliminate those involved in bribery
- Reported potential true hits for review and action
- Screened all additional vendors after the initial review
Risk assessment
- Identified control gaps in key high-risk processes such as T&E, gifts, donations, and complimentary/promotional products, and performed sample testing for operational effectiveness
- Identified root causes for control gaps and recommended a comparative framework to formulate guidelines for mitigating corruption risks
Data analytics
- Performed FCPA analytics on the T&E and complimentary/promotional product categories to identify and understand FCPA red flags
Impact
A clean house, happier FCPA officials—and millions of dollars in savings
Genpact delivered more robust compliance in addition to significant savings by:
- Identifying 24 potential blacklisted vendors doing business worth $10 million with the company
- Eliminating blacklisted vendors, which saved the company millions of dollars in penalties
What’s more, we also:
- Identified places in the marketing process where people were misusing complementary products
- Created a framework for periodic screening to report FCPA sanctions for existing vendors, and recommended screening for new suppliers
- Delivered a robust FCPA compliance and anti-corruption monitoring framework
- Enabled an enhanced control and compliance environment