Every worthy act is difficult. Ascent is always difficult. Descent is easy and often slippery.

—Mahatma Gandhi

One of my clients was dealing with the aftermath of a major investigation that had implicated senior executives of the company in an elaborate bribery scheme by which millions of dollars had been funnelled to government officials through third-party agents. The Board-mandated investigation also found the company's anti-corruption compliance programme to be severely deficient; the vetting and oversight of agents in emerging markets was poor to non-existent. As grim headlines piled up, the customer base haemorrhaged, and the stock price tanked, the company cautiously embarked on a remediation campaign based on the findings of the Board's investigation. Realizing that the company was at a crossroads – and that failure was not an option – the Board Chair sought some outside validation. Among other steps, he retained my firm to provide an independent assessment of the company's progress in carrying out the remedial measures.

Over the course of a three-week engagement, our team surveyed the scene, interviewed the key players, and dug deep into the investigation files. Considering the severity of the allegations, we found the current remediation approach – designed by external counsel at the behest of the Audit Committee – to be far too limited and fragmentary. It was designed to fill a few procedural gaps rather than ...

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