One area of potential FCPA risk that doesn’t get much attention, or as much as it should, is how companies meet their Corporate Social Responsibility (CSR) objectives on mega projects (oil, gas, mining, infrastructure, etc.). Without the proper systems in place, and properly trained staff, project directors and CSR managers may inadvertently violate the FCPA by providing something of value to a foreign official to alleviate delays caused by conflict in the community.
Entries in corporate responsibility program (3)
This post is the third and last in a series exploring the topic of conflict minerals.
In Part one, examined the origins of the reporting requirement. In Part two, we explored what constitutes sufficient due diligence in an investigation of a company and its supply chain.
Part three gives a nonexhaustive checklist of compliance best practices that companies can consult to begin their examination and reporting activities.