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Energy companies could face risks by using third parties

Integrity compliance and integrity due diligence are crucial to companies with international operations. David Lister and Gavin Proudly of EY look at the key issues, and at how oil and gas companies are tackling them

The risks are clear. Energy companies can face highly disruptive investigations into allegations of bribery and corruption as a result of the actions of third parties operating abroad on their behalf. The need to ensure compliance with integrity legislation and to carry out thorough integrity due diligence is pressing. Take the US, for example. Kara Brockmeyer, the head of the Foreign Corrupt Practices Act (FCPA) Unit at the US Securities and Exchange Commission (SEC), noted last year that over 60% of FCPA cases involved third-party intermediaries. In the past year alone, enforcement action in the oil and gas sector has focused on an agent with political connections, a company’s bank manager

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