A PATH TO REFORM AND CHANGE

In the middle of difficulty lies opportunity.

—Albert Einstein

In the Introduction to this book, I mentioned my work with a global manufacturer headquartered in Germany. It was success story about a company's evolution from crisis to transformation. It was also a 10-year odyssey with many ups and downs.

Here's one piece of the story I didn't include in that short synopsis.

Several years into my relationship with the company, on a review of its ethics and compliance programme in an Asian market, my team discovered that a former sales employee who had been terminated four years prior for her participation in a bribery scheme was currently employed by one of the company's largest joint-venture partners in the region. She was continuing to sell the company's products to high-risk customers in emerging markets, but doing so through the partner firm instead. To make it even more ‘interesting’, her new firm was located in the same building as her former employer, on a higher floor.

The company's continuing relationship with a former employee who had been terminated because of integrity concerns was obviously a serious compliance blind spot. This was a disturbing discovery for me because it revealed that even several years into the company's rebuilding process, they were effectively continuing to ‘outsource’ their corruption problem – two floors up.

It was an important lesson for everyone working on this case. We had dealt with the immediate crisis. We ...

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