My friend Donna Boehme is looking for feedback. She wrote to me as follows:
“You have probably seen the news that the OECD Working Group on Foreign Bribery has issued a Good Practice Guidance relating to anti-bribery compliance programs. Joe Murphy and I have been participating in this process, and Joe represented SCCE in the Working Group’s programs as a Consultative Partner; we both attended the Dec 9 launch of the GPG by OECD in Paris. We believe this standard actually offers a very useful template for all types of compliance and ethics programs. It has the enormous advantage of being the first truly international standard, since it has been signed off on by the 30 OECD countries plus 8 other signatories to the anti-bribery convention. In a sense it is the “global sentencing guidelines” in terms of its potential impact globally. I have attached our comment draft, which we are circulating broadly for review and comment, including to the OECD and US Sentencing Commission. I’d be interested in any thoughts/input on the draft. Please also feel free to share it with anyone you think might share the interest. We think this OECD Guidance has tremendous potential to expand what was started by the US Sentencing Commission further onto the global stage.
Cheers, Donna
Document is here:
