DLA Piper Global Law Firm
Global Governance and Compliance
Global Governance and Compliance
Represented the audit committee of a multinational technology company in an internal investigation focused on whether certain payments made by the company’s India operations were made improperly and in possible violation of the FCPA and other applicable laws. As part of the engagement, we coordinate with local counsel and the company’s local and global financial auditors. We advised the client on remediation to its global compliance and ethics program. The scope of the remediation not only included the anticorruption compliance program, but also advice on strengthening the core ethics component of its global corporate compliance program.
Assisting a major multi-national cosmetics company to design, manage and implement a series of compliance initiatives in its APAC, EMEA, LATAM and North American markets. We worked together to update a pre-existing global compliance risk assessment, designed and implemented a compliance monitoring program, worked with internal audit to improve the auditing of the compliance management function, revised investigation protocols to improve efficiency and protect the applicable privileges, drafted or revised numerous compliance policies (including anti-corruption, gift-giving/hosting, trade sanctions, conflict of interest, social media, free merchandise, cash advance, direct government engagements and third-party vendor due diligence), and developed a global training plan. We also conducted an objective risk assessment on third-party vendors, designed an effective due diligence program for the vendor base, and administered the due diligence process on those vendors that presented the highest risk.
Undertaking a comprehensive review of data privacy laws in 67 jurisdictions for a leading global bank. This brought together advice from across the globe on key data privacy issues including: basic data privacy requirements in each jurisdiction; banking secrecy, the interaction of data privacy and HR; CCTV and employee monitoring; IT organization, management and security; the use of personal data in marketing; the use of personal data on the internet and
organizations’ intranet; and cross-border transfers
Advising Hyundai and Kia in relation to global compliance work relating to ABC. As part of this process, lawyers from our offices in Seoul, Germany and Brazil, have conducted multiple anti-bribery and anti-trust compliance training sessions at Hyundai Motor and KIA Motors' plant locations around the world.
Acting as the Compliance Officer for a multi-billion dollar energy transportation company. This role involved conducting anti-bribery due diligence on numerous bidding entities and advising on the associated risk, advising on policies and procedures, training the Board and third parties and advising on measures required of contractors to ensure bribery risks were minimized as far as possible.
Advising an international insurance company, following a full scale and intensive review of the client’s compliance framework and suite of policy documentation, on developing its Australian whistle-blower policy and to work with and train all of the key stakeholders (including the company’s board and senior executives) on their obligations under the policy.
Continuing to provide a major pharmaceutical company with compliance counsel and assistance in further developing and honing the company's global compliance programs and processes - including as compliance counsel in an ongoing monitorship with the SEC.
Conducting a multi-jurisdictional compliance risk assessment and 'health check' for a FTSE 250 gambling company which covered: Anti-Bribery & Corruption, Anti-Money Laundering, Ethics, the Criminal Finances Act 2017, Responsible Gambling, and Human & Labour Rights. The risk assessment included a review of existing policies and procedures, multiple interviews across the business, and a compliance questionnaire. Our findings were then analyzed to produce a risk matrix, a heat map and a findings report. A multi-jurisdictional training program was then rolled out across the business which factored in the key learning points.
Assisting a leading Italian based multinational group in the oil, gas and power industry in updating the ex post (after the perpetration of a crime) organizational, management and control model, with a specific focus on safety rules, following legal issues relating to the kidnapping of four employees of the company in Libya.