Investigations and
monitorship support
When an organisation faces allegations of fraud, bribery or corruption it needs to understand, in detail, the full nature of the allegations and the extent to which any wrongdoing may have taken place.
What we do
GoodCorporation’s extensive anti-bribery and corruption experience make it well placed to provide a range of monitorship, debarment and investigation support to help companies manage these difficult challenges to their business.
Investigations and monitoring support
GoodCorporation works with companies facing investigation, monitorship or debarment to test, strengthen and evaluate their compliance programmes. Our detailed investigation work enables companies to understand the full extent of any wrongdoing. It is also used to provide the basis for subsequent decision-making and future actions. We work with companies who are under investigation by regulatory authorities. We perform the duties of a monitor to assess, revise and strengthen practices and procedures to help deliver sustained and continuous improvement. We help design and implement ‘corporate renewal’ programmes and use our benchmarking to evidence that improvements are being made over time. GoodCorporation is experienced in working with regulatory bodies. Please see the table below for examples of the industries we have worked in.
Mining
LAW
UK Bribery Act
AUTHORITY
Serious Fraud Office
CG ROLE
Anti-corruption adequate
procedures measurement
MONITORSHIP
Pre-monitorship
Oil/gas
LAW
Oil for Food
Programme
AUTHORITY
UN
CG ROLE
Inputting data on
compliance to the monitor
MONITORSHIP
Monitor appointed by the
DoJ
Defence
LAW
UK anti-
corruption
laws
AUTHORITY
Serious Fraud
Office
CG ROLE
Evaluating companVs
internal audit function
MONITORSHIP
Working under Lord Woolf
Equipment procurement
LAW
UK Bribery Act
AUTHORITY
Serious Fraud Office
CG ROLE
Anti-corruption adequate
procedures measurement
MONITORSHIP
GoodCorporation acted as
the SFO’s ‘mini-monitor’
Construction
LAW
Foreign
Corrupt
Practices Act
AUTHORITY
US army
CG ROLE
Anti-corruption effective
compliance programme
measurement
MONITORSHIP
Working with Professor
Mark Pieth
Logistics
LAW
UK Bribery Act
AUTHORITY
Serious Fraud Office
CG ROLE
Anti-corruption adequate
procedures measurement
MONITORSHIP
No monitor appointed as
yet, case still in court
Oil/gas
LAW
Foreign
Corrupt
Practices Act
AUTHORITY
US Department
of Justice
CG ROLE
Anti-corruption effective
compliance programme
measurement
MONITORSHIP
GoodCorporation reported
to DOJ undera Halliburton
ruling via an external
lawyer
Oil/gas services
LAW
Brazilian anti-
corruption law
AUTHORITY
Government of
Brazil
CG ROLE
Anti-corruption adequate
procedures measurement
MONITORSHIP
Client is on Petrobras
watch list, but no monitor
appointed
Construction
LAW
UK Bribery Act
AUTHORITY
Serious Fraud Office
CG ROLE
Anti-corruption adequate
procedures measurement
MONITORSHIP
Case was dropped by SFO
after GoodCorporation
data was resented
Global bank
LAW
Loi Sapin II
AUTHORITY
European
Regulator
CG ROLE
Review of due diligence
procedures focusing on
ABC, AMI, and KYC checks
MONITORSHIP
DPA equivalent
Engineering firm
LAW
Loi Sapin II
AUTHORITY
European
Regulator
CG ROLE
Review of ABC and fraud
risk mapping
MONITORSHIP
DPA equivalent
Global high security printing firm
LAW
Swiss Criminal
Code
AUTHORITY
OAG,
Switzerland
CG ROLE
Banknote Ethics Initiative
MONITORSHIP
GoodCorporation’s
assessment report and
benchmarking were
presented to the OAG, no
monitor appointed
Conducting detailed
investigations of misconduct
Conducting detailed
investigations of misconduct
Using the Logickull eDiscovery platform, we assist our clients in performing detailed investigation work. Logickull provides a cost-effective and rapid way to review large volumes of documentation within a secure environment.
Such detailed investigation work provides a sound basis for any necessary decision-making and the subsequent actions required. Should it be necessary, we are also able to conduct witness interviews and act under legal privilege when commissioned in the appropriate way. Using Logickull we are able to:Â
Review email records
Upload process and tag documents at speed
Identify any anomalies
Identifiy implicated parties
Conduct extensive searches of emails, messaging chats, documents, accounting databases, websites and other electronic information held
Review physical and digital documents related to relevant transactions
Apply a tagging system that enables documents to be prioritised, stored and indexed for different searches.
Cross-check emails and financial records
Managing monitorships
and debarments
Working with a monitor or responding to an actual or potential debarment can be an enormous challenge. For companies facing these difficulties, we use our Anti-Corruption and Integrity Compliance Frameworks to test, strengthen and evaluate compliance programmes.Â
GoodCorporation has conducted internal investigations of alleged corruption and also worked with organisations under investigation. This enables companies to:Â
Define any failures and their causes
Assess the controls that exist and how well they are applied
Prepare a programme of mediation to embed adequate procedures
Provide the evidence needed to demonstrate sustained and continuous improvement
Building a defence when facing
prosecution for corruption or debarment
Building a defence when facing prosecution or debarment is a critical and time consuming exercise. In our podcast below, Leo Martin explains how GoodCorporation’s range of services can help.
This includes:
The podcast explores:
The use of benchmarking to provide evidence that adequate procedures are in place to prevent bribery
Applying GoodCorporation’s integrity analysis methodology to demonstrate that local controls to prevent fraud, corruption, collusion and coercive practices are in place and functioning.Â
We couldn’t believe the speed and responsiveness of your team. Everyone was extremely well briefed, knowledgeable and engaged.
GoodCorporation e-Discovery client
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