International procurement and purchasing personnel at all levels of SEC-regulated companies now have a great opportunity to earn huge rewards for confidentially reporting bribery that has occurred at their current jobs (or their former jobs). The Dodd-Frank reward program covers corporate violations of the U.S. Foreign Corrupt Practices Act (FCPA). International whistleblowers who provide information about companies bribing foreign government officials can receive large rewards. The U.S. Securities and Exchange Commission already has made more than $175 million in payments to whistleblowers. This post will discuss how current or former procurement, purchasing, and contracts personnel working in foreign countries may have reward eligible information relating to bribery.
Payments to Suspicious Vendors, Suppliers, Consultants, Agents, and Intermediaries
Procurement and purchasing personnel often learn about their companies engaging and paying suspicious vendors, suppliers, contractors, consultants, agents, and intermediaries to conduct business. Procurement and contracts personnel should be alert to any attempt by management or sales to circumvent third-party due diligence protocols with respect to any vendor, supplier, or consultant. Any attempt by management or sales to prevent a full vetting of a vendor or supplier could indicate corruption.
Oftentimes companies may engage a vendor or contractor who is affiliated with a government decision maker on a sole source basis without adequate due diligence. The contracts for suspicious suppliers are often very vague. If anyone is aware of a company engaging a suspicious vendor or consultant in connection with winning a contract, bid, tender, or deal, then he or she should feel free to email me at email@example.com, as this could be valuable information. For more information and details about how the reward program applies to FCPA whistleblowers, please click here.