Compliance Programs to Prevent Corporate Misconduct

With the proliferation of official investigations into international bribery allegations in recent years, as well as the huge fines imposed as a consequence of such investigations, much of the attention of the compliance community has lately been focused on anti-bribery efforts. However, equally important and potentially damaging for an employer is possible corporate misconduct by its employees, perpetrated within the scope of the activities of the company. In fact, recent years have witnessed as many internal investigations into corporate misconduct as internal investigations into corrupt behavior. Most commonly, corporate misconduct may manifest itself in the shape of criminal acts, such as misappropriation of assets, forgery of documents, and fraud, or sometimes in the guise of ordinarily non-criminal acts, such as conflicts of interest. Not only may companies be the victims of such employee behavior; in cases of fraud committed by an employee within the scope of the