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Anti-Corruption Due Diligence on Multinational Third Parties

  • 1.  Anti-Corruption Due Diligence on Multinational Third Parties

    Posted 09-07-2022 09:51 AM

    At Xylem, we are looking to benchmark how others are conducting anti-corruption due diligence on multinational companies (for example, a freight forwarder with a parent company located in a country known for lower risk, but with dozens of affiliates globally, some in countries deemed higher risk for corruption. The "affiliates" may be subsidiaries, but are often subcontractors).

     Specifically, we are wondering if others are ordering due diligence reports and requesting compliance certification, due diligence questionnaire completion, etc.:

    • for each associated affiliate entity where your company is doing business
    • only at the parent level (i.e., a comprehensive global anti-corruption review) or
    • some other combination – (such as the parent level and top 5 highest risk affiliates, etc.)

     If you are ordering due diligence at the parent level for a “global review” of its affiliates, are you doing so through your regular due diligence vendor?

      • Are you willing to share the vendors who are able to produce a global anti-corruption due diligence report?


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    Ann Kulow
    Global Ethics & Compliance Manager
    Xylem Inc.
    Dousman,WI
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