Several compliance officers have indeed been questioned by authorities during judicial investigations and have even been subjected to personal investigations. Authorities naturally try to determine what exactly the compliance officer was aware of in any given corruption allegation.
Whether at headquarter or subsidiary level, compliance officers commonly wonder what their judicial responsibilities would be in the event of an investigation into an alleged act of corruption.
I understand very well that operational people in the companies are saying: “Please, do not issue new guidance. We are already not able to deal with the existing ones.”
The UK Law Commission (LC) was tasked with drafting a suitable Bribery Act. I was part of the LC Advisory Panel. Originally, it was to be for a new Corruption Act but that was the first thing we ditched because bribery is easier to define than corruption.
The Global Principles of Business Ethics is an initiative launched by both the Aerospace Industries Association of America (AIA) and the Aerospace and Defence Industries Association of Europe (ASD).
For the last few years, the Brazilian society has been voicing their collective dissatisfaction with continual cases of endemic corruption, especially the ones emanating from the political bodies. After finally ascending to power in the early 2000’s, the Labor Party was expected to bring a higher level of ethics to the way government (at all levels; federal, state, municipal, etc.) conducts itself.