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The Anti-Corruption Law Program: Corporations in the Era of Compliance - Developing Robust Internal Compliance Programs
Thursday, November 24, 2016
Deloitte LLP Offices, Bentall 4, Vancouver, BC
Corporate compliance programs represent an important anti-corruption tool, if well designed and implemented. While the basics of anti-corruption compliance program design are now well known, there is much to be learned from knowledgeable practitioners regarding the difference between a “paper” compliance program and one that is truly effective.
This three –hour Seminar will provide an opportunity for participants to explore with a knowledgeable panel the key elements of effective anti-corruption compliance programs. The panel will address important questions about the design and operation of defensible compliance programs such as:
- How does the introduction of ISO 37001 change the landscape for those who design and implement compliance programs?
- Are there legal norms that can assist in ensuring that a compliance program of a Canadian company meets domestic and/or international standards?
- What are the most common areas in which compliance programs have been found to be insufficient in their design, resourcing or application?
- When your company is under the magnifying glass of a FCPA or CFPOA investigation – do you go all the way through to internationally-recognized “gold standard” for compliance programs – or is risk tolerance is still on the table when implementing improvements to your program?
- After a media and/or legal storm of an investigation or prosecution has passed, how do you protect a compliance program against being cut back as a result of new budget pressures and the temptation to “loosen up”?
- At what stage should your company feel comfortable about terminating the services of a consultant company that has been overseeing the design and initial operation of your compliance program?
- How would a monitor imposed as part of settlement with the government of a corruption related offence affect your compliance program?
Our panelists represent many years of experience with designing, implementing and monitoring
effective compliance programs:
Carol Buckton - Regional Compliance Officer, Canada – Siemens.
Carol Buckton joined Siemens in 1986 and since then has held a variety of positions initially
within the Finance department. In 2004, under Ms. Buckton’s leadership, the Logistics and
Export Control and Customs functions were carved out of Finance and a newly created Trade
Logistics Department was formed. In 2010, she assumed responsibility for Indirect Materials Procurement and then 4 months later for the overall SCM function at Siemens Canada. In this
role, Ms. Buckton was responsible for combining the Logistics, ECC and Indirect Material
functions into the newly created SCM department. In 2014, Ms. Buckton moved from Supply
Chain Management to assume the role of Lead Regional Compliance Officer for Siemens in
Canada. In this function she is responsible for all Compliance related activities including Data
Privacy, Anti-Money Laundering and Collective Action initiatives. In addition to her role as
Compliance Officer, Ms. Buckton continues to act in the capacity of Export Control and
Carol is a member of the Board of Directors of the Ethics Centre and the Professional Logistics Association and is also a member of the Supply Chain Advisory Committee of Seneca College. Additionally, she is active in other associations, including the Canadian Manufacturers and Exporters Association.
Kevin Duggan – Corporal, E Division, RCMP
Kevin is a member of the RCMP’s “E” Division Federal Serious & Organized Crime Financial Integrity Team, with over 18 years in the RCMP, including specialized experience in the Integrated Proceeds of Crime program, and Federal Drug Enforcement. From 2008 to 2013, he was a member of the RCMP‘s International Anti-Corruption Unit, conducting investigations of Canadian individuals and companies involved in the bribing of foreign public officials. Kevin was the Primary Investigator in the landmark Niko Resources case, and the File Coordinator for the Griffiths Energy case. Kevin acted as the Probation Officer for Niko Resources, monitoring the court-appointed auditors efforts to ensure Niko established and enforced an anti-corruption compliance code. In 2013, he provided training support to Japan’s corruption investigators as part of the OECD Technical Delegation on Combatting Bribery. He has delivered lectures on Foreign Bribery investigations to academic, business, legal, and law enforcement audiences in Canada, the US, and Hong Kong.
Donna Fuller - Partner, Financial Advisory, Deloitte LLP
Donna leads the forensic and anticorruption consulting practice of Deloitte in Vancouver. She specializes in financial crime investigations and providing diligence and regulatory services to domestic and international companies. Prior to joining the Vancouver forensic practice in 2016, Donna spent a total of 15 years in the practices of Deloitte in New York and São Paulo, where she led numerous FCPA investigations, acquisition due diligence inquiries, and proactive risk assessments and compliance efforts in the Americas, Europe, and Asia for clients representing a wide range of industries. Ms. Fuller has appeared multiple times before the U.S. Department of Justice and Securities and Exchange Commission to present investigative findings and compliance remediation plans and updates.
Donna was in Brazil when the Brazil anticorruption law became effective and she helped both multinational and domestic Brazilian companies with their efforts to comply with the legislation, including training of employees, third party diligence and assessment of anticorruption policies and procedures.
Diego Venegas - Director, Internal Audit and Ethics, Goldcorp Inc.
Diego is a key contributor and director of Goldcorp’s Ethics and Compliance program. Goldcorp is one of the largest gold mining companies in the world by market cap and has operations and development projects throughout the Americas. For the majority of his career, he has been focused on strengthening organizational control environments, first focusing on financial reporting and process-level controls, and then placing significant emphasis on entity, governance and cultural-level controls. Due to his background, Diego currently holds a shared role between Ethics and Compliance and Internal Audit. Over the past 14 years Mr. Venegas has traveled extensively and worked in various and very different cultures and jurisdictions, including Canada, the US, Mexico, Guatemala, Honduras, Brazil, Venezuela, Chile, Argentina and Peru. This international exposure has allowed Mr. Venegas to leverage cultural differences as a key design component of each of the programs designed and implemented by his office.
Diego is a Board Member and Treasurer of Transparency International Canada, a Certified Internal Auditor by the Institute of Internal Auditors, and is a Certified Fraud Examiner by the Association of Certified Fraud Examiners. Prior to joining the mining industry, Mr. Venegas was a senior risk consultant at Ernst & Young in Canada and in Peru.
To register please email John Ritchie at firstname.lastname@example.org. Suggested readings will be circulated to those that register. Also please note that we expect that attendance at the event will qualify you for 3 Continuing Professional Development credits if you are a lawyer practicing in BC.
It will be important to know the names and email addresses of participants well in advance of the meeting, to allow us to email reading materials to registered participants, and to plan for meeting space and coffee. Please indicate by email to John Ritchie as soon as possible if you will attend.
Location: Offices of Deloitte LLP at Bentall 4 (Burrard and Dunsmuir), Vancouver. The meeting room is located on the 26th floor. Please report to Reception on the 28th floor about 15 minutes before the scheduled start of the meeting.
Cost: There will be no charge for this event. Deloitte has kindly agreed to provide meeting space and coffee free of charge, and our speaker and panelists will attend at their own expense.