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“Corporate executives may be tempted …to invest fewer resources in their compliance efforts. …. I caution you in this regard. The Department is looking carefully at lapses - both past, present, and future - in corporate compliance.”
– Lanny A. Breuer, Assistant Attorney General, Criminal Division, U.S. Department of Justice
EXAMPLES OF OUR WORK
CSLG was founded more than a decade ago. In that period, we have worked on an exceedingly broad range of projects for over 75 companies and other organizations. We generally work for the private sector, but we have served as independent evaluators producing reports on company compliance/ethics programs for multiple government agencies, and have twice been hired directly by the Department of Justice to evaluate the compliance/ethics programs of public companies.
Typical examples of work we do:
- International Bribery/FCPA – We were retained, with the approval of the U.S. Securities and Exchange Commission, to assess the anti-corruption compliance initiatives of a large global company pursuant to an agreement between the SEC and the company in a widely publicized case. We conducted our review primarily in Asia/Pacific and the Middle East and our report went jointly to the company and the SEC.
- Risk Assessment – We were retained by a leading consumer products company to help the company develop a best-in-class, worldwide risk assessment process. The process led to the review and prioritization of about 70 compliance/ethics risk topics and established within the company an ongoing internal risk assessment process.
- “Longitudinal” Program Evaluation – We were retained by one of the world’s largest corporations – a conglomerate with highly diverse businesses – to assess the effectiveness of the company’s compliance/ethics program globally. Using a combination of confidential interviews, focus groups, document reviews and the company’s own survey data, we reported to management and the board on strengths and opportunities for improvement. The company implemented our recommendations and then retained us again three years later to validate improvement.
- Strategic Counseling to Enhance Program – We have been retained by numerous companies, with some of the world’s best known brands, to help them move their programs forward. We have provided advice and implementation assistance with respect to, for example, the structure of the compliance/ethics function (e.g., positioning of the compliance/ethics officer, role of compliance committee, board charter), standards and policies for the company (including revising the code of conduct to be relevant, user friendly and readable), and program evaluation (including constructing a best practice employee survey).
- Federal Sentencing Guidelines Opinion – We were retained by a large aerospace company to provide an opinion about whether the company’s compliance/ethics program met the Federal Sentencing Guidelines standards so that the company could, in turn, make a required certification to the government.
- Helpline and Internal Reporting – One of the country’s largest transportation companies retained us to undertake a comprehensive analysis of the systems the company relies on to encourage employees to raise compliance/ethics questions and concerns.
- Evaluation at Acquired Company – After indications of possible non-compliance at a recently acquired subsidiary, we were retained to test the degree to which a parent company’s compliance/ethics program had culturally “taken hold” at the subsidiary. Our work included site work in North America, South America and Asia.
- Strategic Advice on Relationship Between Non-U.S. Parent and U.S. Subsidiary – We have been retained by non-U.S. companies to help them determine an effective, culturally appropriate relationship between the parent’s compliance/ethics program and that of its U.S. subsidiary.
- International Program Evaluation Pursuant to U.S. Consent Decree – We evaluated the compliance/ethics program of a company that had entered into a deferred prosecution agreement for alleged fraud by some of its employees. Pursuant to the agreement with the government, we evaluated the effectiveness of the company’s program by conducting on-the-ground evaluations at company operations in Eastern Europe, the Middle East, the U.S. and the Caribbean.
- Training – We have been retained to provide training on compliance-related topics, ranging from antitrust, to developments in the legal landscape of compliance, to boards of directors, management groups and specific departments, such as sales.