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FCPA practical considerations for companies operating in Poland. Unconventional Gas Committee Meeting Warsaw, May 8, 2012. Agenda. FCPA enforcement - globally Corruption enforcement – Poland Key challenges Key are a s of risk Good practices. FCPA enforcement - globally.

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fcpa practical considerations for companies operating in poland

FCPA practical considerations for companies operating in Poland

Unconventional Gas Committee Meeting

Warsaw, May 8, 2012

agenda
Agenda
  • FCPA enforcement - globally
  • Corruption enforcement – Poland
  • Key challenges
  • Key areas of risk
  • Good practices
fcpa enforcement globally
FCPA enforcement - globally
  • Enforcement is still on the rise
  • Continued focus on prosecution of individuals

Source: Shearman & Sterling FCPA Digest, January 2012

fcpa enforcement globally continued
FCPA enforcement – globally (continued)
  • Energy sector remains the most affected*

Source: http://fcpamap.com/

  • FCPA definitions remains to be interpreted in an extended way
  • Increased international co-operations amongst regulators
  • Dodds-Frank reform stimulate whistleblowing activity
  • US enforcement activities followed by other countries
corruption enforcement poland
Corruption enforcement - Poland
  • Strong enforcement, especially after fall 2011
  • Number of enforcement agencies
  • Immediate media attention
  • Sometimes – cases started by accident
  • Easy wins for police and prosecutors
  • Wide range of tools used
  • Agencies more effective in submitting charges, then in securing convictions
  • Industry focus
key challenges
Key challenges
  • Corruption is still a big problem although situation theoretically improves
  • Nepotisms, conflict of interest and fraud at local authorities level still remains a big problem
  • Financial turbulences stimulate an increase of pressure
  • Cultural issues still remain unsolved
  • Compliance remains perceived as a form over substance exercise
key challenges ongoing willingness to pay bribes 2012 global fraud survey
Key challengesOngoing willingness to pay bribes (2012 Global Fraud Survey)

Shown: percent stating response

Q3: Which, if any, of the following do you feel can be justified if they help a business survive an economic downturn?

Base: all respondents in Poland (55), Central & Eastern Europe (405), Global (1758)

key areas of risk
Key areas of risk
  • Direct payments
    • Vendors
    • Employees
    • Consultants / experts
  • Indirect payments
    • Intermediaries
    • Agents
    • Sub-contractors
  • Hospitality
good practices
Good practices
  • Hire the right people
  • Lead by example
  • Establish proper policies and procedures
    • Code of conduct
    • Procedures
    • Approval limits
    • Contracts (with FCPA clauses)
  • Have an effective systems of controls over spendings
  • Know your vendors
  • Trust but audit
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