Behind the Bribe – A Fireside Chat with Richard Bistrong
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Richard Bistrong
Jimmy Lin
Anti‐bribery Consultant
The Network
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Speaker Introduction
Richard Bistrong Richard Bistrong spent much of his career as an international sales executive and currently speaks, writes, and consults on FCPA and anti bribery compliance issues from that perspective
on FCPA and anti‐bribery compliance issues from that perspective.
In 2007, as part of a cooperation agreement with the United States Department of Justice and subsequent Immunity from Prosecution in the UK Richard assisted the United States and other governments in
the UK, Richard assisted the United States and other governments in their understanding of how FCPA violations occurred and operated in international sales. Bistrong’s cooperation, including covert cooperation, covered five years, and was one of the longest in US white‐collar criminal investigations In 2012 Mr Bistrong was
white‐collar criminal investigations. In 2012, Mr. Bistrong was sentenced as part of his own Plea Agreement, and served fourteen‐
and‐a‐half months at a Federal Prison Camp.
Richard now blogs at www.richardbistrong.com and consults with organizations via his consulting practice Front‐Line Anti‐Bribery LLC, about current FCPA and anti‐bribery compliance issues, drawing from his own perspective to discuss trends and compliance challenges, especially as they might impact overseas business executives and groups. Speaker Introduction
Jimmy Lin is the Vice President of Product Management & Corporate Development for The Network. Jimmy leads corporate and product strategies for The Network’s Integrated GRC Solutions. He has over 14 years experience in and around software and technology, from implementing software to gy
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analyzing new markets and leading product strategies for organizations like Oversight Systems, Manhattan Associates, UPS Supply Chain Solutions and IP2Biz. Jimmy is a Certified GRC Professional (GRCP).
From “Behind The Bribe” A Fireside Chat with The Network GRC
A Deep Dive into the White Paper
The Network GRC & Richard Bistrong, 2015
A Fireside Chat
Today: Why Talk About the “Dark Side”?
Sample
slide
• I survived a difficult series of events.
• Was my front-line experience all that
unique?
• What were my emotions,
rationalizations and temptations. I
knew it was illegal, so why break the
law?
• Does this story have value for today’s
anti-bribery and compliance
challenges? Calibrating real risk
risk.
• Is there sufficient focus on “dark side”
behaviors at the field level?
www.richardbistrong.com
The Network GRC, 2015, © RichardBistrong
@richardbistrong
A Fireside Chat
My Journey
Sample slide
•
1984 BA
1984:
BA, U
University
i
it off R
Rochester.
h t
IInstitute
tit t off European
E
Studies,
St di
Vienna
Vi
with
ith
honors cum laude
•
1986: MA, University of Virginia, Foreign Affairs: WH Fellowship offer
•
1987: Fourth Generation in family business: Largest Manufacturer of bullet
resistant products when business was sold in 1992
•
1995: Starts career as US Sales VP in a publically traded Defense and LE
Contractor.
Contractor
•
1998: Intl Sales VP: Overseas 250 days per year, lived in UK part time
•
2007: Terminated by employer, called in by DOJ, started five years of US/UK LE
covertt and
d trial
t i l cooperation
ti as partt off US Plea
Pl and
d UK IImmunity
it
•
2012: Sentenced to 18 months, served 14.5 and released in Dec. 2013
•
2014: Engage with compliance community on front-line and behavioral issues.
www.richardbistrong.com
The Network GRC 2015, © Richard Bistrong
@richardbistrong
A Fireside Chat
Poll Question #1
Sample slide
Is your compliance program calibrated to specific regional
corruption risk,
risk or is it a general anti
anti-bribery
bribery program?
• Specific, Regional Corruption
• General, Anti-bribery Program
• II'm
m not sure
www.richardbistrong.com
The Network GRC, 2015, © RichardBistrong
@richardbistrong
A Fireside Chat
Poll Question #1 - RESULTS
Sample slide
IIs your compliance
li
program calibrated
lib t d tto specific
ifi regional
i
l
corruption risk, or is it a general anti-bribery program?
www.richardbistrong.com
The Network GRC, 2015, © RichardBistrong
@richardbistrong
A Fireside Chat
The Distance Between the Law & the Front Line
Sample slide
Regulations
Laws
Policies
C-Suite
Procedures
Execs
Goal: Drive and execute individual compliant
behavior at the front-lines of international business
www.richardbistrong.com
The Network GRC 2015, © Richard Bistrong
Front line:
RISK
@richardbistrong
A Fireside Chat
Confronting Bribery in the Field: My Perfect Storm
Sample slide
No Witnesses
Incentive
Sales Comp
“zero-sum”
Procurement
Instability
“win-big: losebig”
www.richardbistrong.com
to Discussions
“I won’t get
caught.”
No Victim
Illusion
“small bribes”
The
Perfect
Storm
The Network GRC, 2015 © Richard Bistrong
How things get
done around
here. The
“norm”
@richardbistrong
A Fireside Chat
My Perfect Storm: Win-Big Lose Big
Sample slide
Matt Ellis, “Bribes can be baked into the economic order” from
“How to Pay a Bribe,” (Wrage, 2014)
www.richardbistrong.com
The Network GRC 2015 © Richard Bistrong
@richardbistrong
A Fireside Chat
Poll Question #2
Sample slide
Do your incentive packages promote anti-bribery
compliance or are they developed independently of
compliance programs?
• Ours are designed to promote anti-bribery compliance
• Ours are developed independently of our compliance program
• I'm not sure
www.richardbistrong.com
The Network GRC, 2015, © RichardBistrong
@richardbistrong
A Fireside Chat
Poll Question #2 - RESULTS
Sample slide
Do your incentive
D
i
ti packages
k
promote
t anti-bribery
ti b ib
compliance or are they developed independently of
compliance
p
p
programs?
g
www.richardbistrong.com
The Network GRC, 2015, © RichardBistrong
@richardbistrong
A Fireside Chat
My Perfect Storm: Incentives
Sample slide
www.richardbistrong.com
The Network GRC, © Richard Bistrong
@richardbistrong
A Fireside Chat
My Perfect Storm: Breaking the law by nodding
Sample slide
www.richardbistrong.com
The Network GRC 2015, © Richard Bistrong
@richardbistrong
A Fireside Chat
Poll Question #3
Sample slide
Irrespective of the law, do you spend time training and
educating business teams on the societal consequences
of corruption?
• Yes, We have an extensive anti-bribery training program
• Yes, We do some anti-bribery training, no regional focus
• No, Not much time is dedicated to training, they know better
• No, Our training program doesn’t address these issues directly
• I'm not sure.
www.richardbistrong.com
The Network GRC, 2015, © RichardBistrong
@richardbistrong
A Fireside Chat
Poll Question #3 - RESULTS
Sample slide
IIrrespective
ti off the
th law,
l
do
d you spend
d titime training
t i i and
d
educating business teams on the societal consequences
of corruption?
p
www.richardbistrong.com
The Network GRC, 2015, © RichardBistrong
@richardbistrong
A Fireside Chat
My Perfect Storm: The illusion of no victims
Sample slide
www.richardbistrong.com
The Network GRC 2015, © Richard Bistrong
@richardbistrong
A Fireside Chat
My Perfect Storm: The norm and altruism
Sample slide
www.richardbistrong.com
The Network GRC 2015, © Richard Bistrong
@richardbistrong
A Fireside Chat
Poll Question #4
Sample slide
Do you regularly ask your front line international business
teams about the corruption risk they face
face, and what you
can to do help?
• Yes, Regularly.
• Yes, Sometimes, not often enough.
• Rarely, Not unless addressing major policy/change issues.
• No, Never.
• I'm not sure.
www.richardbistrong.com
The Network GRC, 2015, © RichardBistrong
@richardbistrong
A Fireside Chat
Poll Question #4 - RESULTS
Sample slide
Do you regularly
D
l l askk your ffrontt line
li international
i t
ti
lb
business
i
teams about the corruption risk they face, and what you
can to do help?
p
www.richardbistrong.com
The Network GRC, 2015, © RichardBistrong
@richardbistrong
Crime, Cooperation & Compliance
What Might You Do With Today’s Story?
Sample slide
www.richardbistrong.com
The Network GRC 2015, © Richard Bistrong
@richardbistrong
Q&A with the Speaker….
Richard Bistrong
Anti‐Bribery
Anti
Bribery & Compliance & Compliance
Front‐Line Anti‐Bribery, LLC
[email protected]
www.richardbistrong.com
@richardbistrong (Twitter)
Jimmy Lin
Jimmy
Lin
VP Product & Corporate Development
The Network
www.tnwinc.com
@thenetworkinc (Twitter)
THANK YOU!
THANK YOU!
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