Identifying And Mitigating Anti-Corruption And Anti-Trust Compliance Risks

Multi-digit Euro fines for anti-competitive behaviour and continued press coverage of bribes have moved compliance programmes ever more into the focus of attention. They shall help prevent impermissible behaviour, but how to organise a compliance programme?

There are several reasons why undertakings should invest in programmes to safeguard that their business operates in compliance with applicable rules. Beside legal obligations to this end, some consequences of illicit behaviour are too significant to be taken lightly. These may include significant fines; forfeiture of enrichment from the illegal behaviour; administrative, civil and criminal sanctions against individuals; exclusion from public tenders; damage claims by affected customers and significant damage to reputation and share value (not to mention management time lost in dealing with investigations). In turn, effective compliance programmes may bolster credibility and even be criteria of consideration for