It is universally recognized that third-parties are your highest FCPA risk. What if you could turn your third-party from a liability under the FCPA to an innovation partner to your compliance program? This is an area that not many compliance professionals have mined but once again in compliance, you are only limited by your imagination. In a 2015 Supply Chain Management Review article by Jennifer Blackhurst, Pam Manhart and Emily Kohnke, entitled “The Five Key Components for Supply Chain Innovation”, the authors identified five components common to the most successful innovation partnerships.

Don’t settle for the status quo. This means that you should not settle for simply the status quo in compliance.

Hit the road in order to hit your metrics. To truly understand your compliance risk from third-parties, you must get out of the ivory tower and hit the road.

Send prospectors, not auditors. While an audit clause is critical in any third-party contract, both from a commercial and FCPA compliance perspective; you can establish a “point of contact as an innovation manager for your third-parties.”

Show and tell. As with all relationships, trust plays an important role in third-party compliance innovation, as “Firms in successful innovations discussed a willingness to share resources and rewards and to develop their partners’ capabilities.”

Who’s running the show? This means “who is doing what, but also what each firm is bringing to the relationship in terms of resources and capabilities.”

Three key takeaways:

  1. Use your third-parties as innovators to assist your compliance program.
  2. Change your thinking about third-parties and make them your partners.
  3. Do not settle for the status quo.

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