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Bribery Act raised the bar for all of us." Diane Pettie, vice president and general counsel at Canexus Corp., which has a plant in Brazil, says "when you have foreign operations, you need to be aware of these issues and that everyone understands what the laws are and the proper behaviours." Building a compliance program There is no shortage of information for in-house lawyers looking to create a new anti-corruption compliance program or tinker with an existing one. Legal and business advisory firms have swamped the Internet with information on how to build compliance programs. First, it starts with a proper risk assessment. Each company will be different, says McCain's Wessel. "It depends on your business model." Some companies, like food or financial services, will have more regulatory risk while others, such as construction or engineering, will be more involved in bids trying to win business, as opposed to This is your legal community. Stay connected. LEGAL TELEPHONE DIRECTORY British Columbia's vast legal community is right at your fingertips with the 2014 British Columbia Legal Telephone Directory. You get instant access to more than 11,000 lawyers and law offices spanning British Columbia, Northwest Territories, Nunavut and Yukon. And we keep you connected. Now in its 45th edition, each year we ensure this directory includes the most up-to-date names, phone numbers, mailing addresses and emails, so you don't have to search anywhere else. It's all here, instantly, the second you want to network or need legal expertise. Searching is fast and easy with: Durable spiralbound format saves on wear and tear of everyday usage! Get connected and stay connected to your legal community with the 2014 British Columbia Legal Telephone Directory. Order your copy today. Visit carswell.com or call 1.800.387.5164 for a 30-day no-risk evaluation 30 • Lawyers who have implemented anti-corruption compliance programs say to be successful management must be fully on board. "You have to have a clear and consistent tone from the top on what you will and won't tolerate," says Wessel. Desjardins agrees. "It's about culture and the tone from the top more than anything else." He likens today's focus on anti-corruption to the Sarbanes-Oxley reforms following the corporate and accounting scandals of the late 1990s involving Enron Corp. and WorldCom, among others. "It makes us a better and more efficient company." But developing a corruption compliance plan is only half of the solution. Ensuring training and education among staff, suppliers, and contractors is critical to avoiding trouble. Robert Rooney, executive vice president and general counsel of Talisman Energy Inc., says "hands down, the most important thing for general counsel is to get out there and talk about this. So often the focus of the company is on enacting a policy. "It's not enough to have a policy buried on the corporate extranet. You have to make sure they understand it." Manage cultural issues Multiple copy discounts available ntitled-1 1 Tone at the top Education and training INCLUDES BRITISH COLUMBIA, NORTHWEST TERRITORIES, NUNAVUT AND YUKON Also get quick access to: winning over consumers. "My philosophy is to keep it as simple and straightforward as possible and raise the bar to the highest common denominator," Wessel says. o c t ob er 2013 Managing cultural issues is also key to implementation. In jurisdictions where bribery has been an accepted part of doing business, educating staff is crucial. Lendon says, "I think carrying on business in other jurisdictions compels you not to just pay attention to applicable laws, but the culture. You need to take that into consideration in your compliance program. There is a cultural aspect you really have to pay attention to in training." Beware of agents When it comes to corruption, one of the biggest danger zones involves agents. Robidoux notes companies hire agents to help them open new markets, get licences, INHOUSE 13-08-27 2:21 PM

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