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TPRM Report EBA & Co. Final

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  Setting a Clear Path for Business Growth by Addressing Third Party Risks  Let us take a closer look at how companies can rise to these challenges. The business landscape of recent years is seeing repeating signals of concern and uncertainties regarding how to achieve sustainable growth in the wake of regulatory activism, reputational hazards and digital transformations. As long as organizations continue to rely on third parties to facilitate their business operations and goals, such challenges and threats are expected to become more frequent and have more impact. Despite the increasing investment in anti-bribery & corruption ( “ ABC ” ) compliance programs, many companies still struggle with addressing the risks presented by their third parties. Meanwhile, investigating and prosecuting authorities are becoming increasingly aware of such challenges and are putting much more focus on understanding the effectiveness of a company ’ s third party management process when determining whether to bring charges, or negotiating plea or other agreements.Therefore, companies should seek out the best possible solution for addressing their own third party risks. We believe that a holistic and tailored third party risk management approach enabled by the right people and technology, may hold the key for companies seeking to sustain growth while protecting their reputation. Our Point of View  Joint Ventures, Consortia Partners, etc. Business Partners Who could be a third party to your business ? Strategic/operational/financial consultants, Security, contractors/sub-contractors. Professional services Lawyers/Legal advisors, Lobbyists, etc. Legal & Regulatory Affairs Distributors, resellers, Sales agents, etc. Distribution/Sales Warehouse operators, Transportation services, Freight forwarders, etc. Logistics/Storage Raw materials, consumables, hardware/software, etc. Suppliers/Vendors  As in previous years, the relative number of bribery and corruption cases involving third parties continues to increase persistently. This reality suggests that third parties perhaps play one of the biggest roles in shaping the goals of anti-bribery and corruption programs. 2125425461713281614121310152613143 0.0010.0020.0030.0040.0050.0060.00 19982000200220042006200820102012201420162018AllThird Parties Involved ~90% Yearly Average # of Third Parties Involved in FCPA Enforcement Actions 1 1 Source: http://fcpa.stanford.edu/chart-intermediary.html Highlights from Kroll ’ s Anti-Bribery & Corruption Benchmark Report of 2018 55%45% 45% of respondents engage more than 1,000 third parties. 2018 How many third parties do you have ? 40%14%10%8%0%12%7%6%2%35%18%11%8%8%7%7%5%1% 0.00% 20172018 How concerned are you ? Third-party violations top the list of perceived risks to an organization ’ s anti-bribery and corruption program, representing 35% of responses. Third party violationsRegulatory LandscapeLack of resources or proper controls Risks related to joint venture or M&A activityLack of appropriate cyber security  / data protection measuresEmployees making improper payments Lack of sufficient automation or monitoring tools Lack of support for the compliance program from internal leadershipOther
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