Track 3 – EXERCISING THIRD PARTY AUDIT RIGHTS: Experts Reveal How They Have Dealt with a Lack of Third Party Cooperation and Other Pressing, “On the Ground” Challenges

November 29, 2017 4:15pm

Kimberly Walker
Chief Compliance Officer
Danaher Water Quality

Marianne Ibrahim
Senior Counsel Compliance & Investigations
Baker Hughes

Suzanne C. Seferian
Health Care Compliance Officer
Johnson & Johnson

Felipe Maldonado Garcia
Compliance & Ethics Director

Panel Moderator

Kathryn Cameron Atkinson
Miller & Chevalier Chartered

At this interactive session, industry experts with extensive third party audit experience will discuss the biggest lessons learned when preparing for and conducting third party audits. Through anecdotal insights, they will focus on how to resolve complex challenges in high risk markets. The speakers will take you through the realities of different types of third party audits and the associated risk factors. The types of audits and issues to be discussed will include:
  • Government ownership
  • Books and records
  • Compliance structure of the third party
  • Third party contracts with downstream third parties
  • Access to records
  • How to perform audits on longstanding vs. new business partners
  • When audits should be done on a routine basis vs. only if there is a potential issue
  • How to evaluate third party compliance with FCPA, and contractual terms and conditions:
    • examining compliance programs and codes of conduct – books, records and accounts of the third party
    • third party subsidiaries, joint ventures or affiliates
    • testing for gifts, travel and entertainment
    • reviewing expense reports for employees in high-risk positions or countries
    • examining commission payments and petty cash activity
    • analyzing the general ledger for high-risk transactions and cash advances