A major, global chemical with a best practice ethics and compliance program had identified several risk areas where it believed it had effective programs but where the risk of non-compliance carried a high potential for significant harm.

In collaboration with management, ELG assessed the company’s Anti-Trust and FCPA programs. The assessments included a review of recent cases and the company’s internal response.

While the company’s overall efforts were found to be adequate and in some specific ways exemplary, the risk exposure was determined to be high. While policies and processes had recently improved, employee perceptions and understanding lagged. In response a more targeted approach to compliance training and audits was recommended and specific implementation strategies were detailed.