Compliance goes global

Here is a list of  Integrity's "Top 12" compliance and ethics concerns for 2007:  

1. Anti-bribery requirements
2. Records management
3. Anti-trust contact with competitors
4. Mutual respect
5. Privacy
6. Financial integrity
7. Conflicts of interest and gifts
8. Careful communication
9. Proper use of computers
10. Information security
11. Export controls
12. Product safety and liability  

You may notice that Sarbanes-Oxley is not listed as a separate item, but clearly, many of these concerns are related to Sarbox. Records management and financial integrity are directly related. Proper use of computers and information security are as well. So it may be that Sarbanes-Oxley and other regulatory regimes, which tend to be cross cutting, are now built into the fabric of compliance programs. It would be hard to conclude that Sarbox is no longer a concern.

Beyond that, what can we say about the list? Well, in 2007, it seemed that globalization really hit home from a compliance point of view. Anti-bribery requirements, anti-trust contact with competitors, privacy, export controls, and product safety and liability each speak to the new global focus at many companies.

This may be good time review your compliance program in light of the overseas business you conduct. We've noted that anti-bribery concerns have really bubbled to the top of the Justice Department's enforcement agenda, but as the list shows, there are other concerns as well. - Jim