Last week, Johnson & Johnson entered into a deferred prosecution agreement with the Justice Department for violating the Foreign Corrupt Practices Act (FCPA). Although the agreement has been touted as novel for the reduced fine J&J received in exchange for cooperating against other companies and individuals, the agreement confirms the importance of assessing FCPA policies and internal controls.
Companies continue to struggle, however, with how corporate policies address FCPA risk. An empirical look at the Codes of Conduct of the Fortune 500 companies provides some answers.
‘Enforcement 40’ for 2020
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