Global Compliance Solutions

The Challenge for Counsel: Achieving Effective Global Compliance in an Increasingly Complex and High-Risk Global Regulatory Environment

Companies and organizations are under an ever-intensifying burden to manage and comply with myriad global rules and regulations. Meeting this challenge is essential to maintaining the enterprise and reputational value of an organization.

• New areas of corporate activity are becoming subject to regulation.
• Existing regulations are becoming more complex and geographically diverse.
• More countries are enacting heavy business regulations, often with potential extraterritorial effect.

The potential consequences of noncompliance – both for organizations and for individual staff members – across a broad range of regulations are often draconian and becoming more so:

• Criminal penalties or other individual sanctions (e.g., director disqualification) are being added to heavy corporate fines and damages claims.
• Organizations must demonstrate they have effectively implemented policies and procedures to avoid or mitigate liability in the event of infringement.
• In our 24 hour global news environment, it is more difficult to limit reputational damage, especially for high-profile global corporations, with potentially far-reaching and unpredictable consequences.
• Failure to meet these new requirements can put your business at a competitive disadvantage (customers in many industries shy away from suppliers whose integrity is in question) and can be a factor in corporate survival.

However, managing the new regulatory environment is not necessary solely to minimize risk, but can also give companies a competitive edge, greater market share and enhanced profitability. In a world of increasing regulatory uncertainty, learning to navigate the landscape will be a key differentiator between companies.

Compliance Solutions
Drafting, reviewing and/or modifying: Corporate compliance statements, programs and handbooks Corporate authorization policies Codes of conduct Compliance-related employment terms/policies Training for boards, executives and relevant staff – both in-person training and online training tools – and follow-up staff evaluation tools	Audits and assessments  Dawn raid response protocols and training Dawn raid rapid response service (and 24 hour hotline) “Mock” dawn raid exercises Policy review and awareness campaigns Hotline for initial compliance queries Blogs and updates Intellectual property portfolio management

Working With You to Achieve Compliance

Squire Sanders has the technical and practical expertise necessary to design and implement compliance solutions that are sensitive to each organization’s culture, way of doing business and economic model. We work with organizations to help ensure that employees are properly educated and incentivized not to engage in infringing conduct without stifling efforts to grow the business. We have also defended organizations in legal challenges to their compliance programs. Squire Sanders offers:

• Global coverage 
• Best practices for compliance 
• Expertise in corporate defense 
• Customized, global efforts effectively implemented locally

Our compliance advice is efficiently and effectively coordinated – across practice groups, industries and borders – and delivered by a team tailored to your individual needs, with (unless you indicate otherwise) a single partner assuming overall responsibility for the delivery of our service.

Success Stories

Designing and Implementing Compliance Solutions for One of the World’s Largest Chemicals Corporations, Resulting in the Successful Defense of a Regulatory Challenge

Throughout the last decade, we have consistently supported one of the world’s largest chemicals corporations in designing and implementing best practice compliance policies, procedures and systems throughout the world in a number of areas of regulation, including antitrust and bribery. We have assisted in:

• Drafting corporate compliance policies
• Implementing safeguard procedures
• Rolling out training programs
• Evaluating ongoing compliance via audits and mock investigation exercises

These efforts directly led to the quick closure of a recent antitrust investigation in Europe and the complete exoneration of our client, including obtaining formal recognition of this from the regulator upon closure of its file, which facilitated our client’s ability to close a major corporate transaction that the investigation would potentially have complicated.

Designing and Implementing Corporate Governance and Authorization Policies for a Large Financial Services Client

We assisted our client in crafting consistent corporate governance and authorization policies to address and mitigate compliance issues arising from the myriad regulations applicable to financial services organizations.

Designing and Implementing an Enhanced Global Compliance Program for a Marketer of Consumer Products

We are assisting our client in all aspects of the design, development and implementation of a global compliance program, including assistance with:

• Restructuring its global compliance function to comply with best practices and recent amendments to sentencing guidelines 
• Developing a new code of conduct 
• Drafting a global anticorruption policy and country-specific awareness campaigns 
• Conducting an enterprise-wide risk assessment 
• Redesigning/updating the global compliance program in combination with the client’s internal ethics and compliance team

Developing and Rolling Out a Global Trade Compliance Program for a Specialty Materials Manufacturing Company With Numerous Plants Throughout the Americas, Asia and Europe

In early 2011, our global import and export team was hired to assist our client by:

• Working with the client’s law department to develop company-wide trade compliance policies and guidelines
• Helping the company establish its global trade compliance team throughout the Americas, Europe and Asia 
• Providing training to the company’s newly established global trade compliance team and assisting it to develop standard operating procedures to implement the new management-approved policies and guidance

Conducting a Market Access Audit for a Client in the Logistics and Food Products Industries

Our global market access/international trade agreements team was hired by our client to:

• Work with the client’s legal, government affairs and business units to inventory trade and regulatory hurdles faced by the client
• Establish procedures for highlighting trade barrier issues for a focused in-house leadership team
• Identify and prioritize those barriers and internal market distortions that could be systematically reduced to improve the regulatory environment faced by our client around the world