1. Internal Process & Due Diligence
VALET - October 15, 2010
Internal Process & Due Diligence
Presented by Michael Runyan

2. Agenda Effective Partnerships Anti-Corruption Landscape Due Diligence
Corporate Culture & Policy
Training & Awareness

3. Effective Partnerships
What is Most Important for Your Business
Quality
Turnaround Time
Price
Expansion

4. Effective Partnerships
Building Relationships
Vendors
Joint Ventures
Intermediaries
Consultants
Employees

5. Effective Partnerships
Who Are You Conducting Business With
Vetted
Ethical Standards
Legal Background
Financial History
Trustworthy

6. Effective Partnerships
What Are the Risks of Business in an Uncertain World

7. Anti-Corruption Landscape
Anti-Bribery Legislation
Foreign Corrupt Practices Act (FCPA) 1977
UK Bribery Act
OECD UN
Foreign Laws
Affects All Transactional Business & Record Keeping

8. Anti-Corruption Landscape
FCPA Enforcement
120 Investigations in 2010
Massive Fines
Criminal Penalties
Global Collaboration
Size or Industry Does Not Matter
Foreman
“He should have known this was going on, it’s his job”

9. Due Diligence Evaluate Risk Determine Relationship
Disclosure Documents
Conduct Inquiries
Scale to Requirements
Uniform Action

10. Due Diligence Identify Red Flags PEP State Owned Non-Disclosure
Expenses
Unlikely Business Partner
Relationships
Financial Concerns
Ongoing Investigations
Debarred/Sanctions
Recommendations

11. Due Diligence Evaluation & Decision Document All Findings
Periodically Review
Know Who You Are Working With
Act Accordingly

12. Corporate Culture & Policy
Culture of Compliance
Employees are the 1st Line of Defense
Know the Company Policy
Top Level Management
Reward Efforts

13. Corporate Culture & Policy
Compliance Program
Guidelines for Operations and Sales
Show the Line
Documented Policies
Agreements Documented
Mitigate Risk
Maintain Integrity – Facilitate Trade

14. Training & Awareness Program Development Mandatory Documented Audit
Periodic Review

15. Training & Awareness Continuous Improvement More than a Paper Program
Know Your Business Partners
Periodically Re-Evaluate

16. We Never Sleep Michael Runyan Managing Director
2001 Jefferson Davis Hwy,
Ste. 407
Arlington, Virginia 22202 O F C
We Never Sleep
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