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Anti-Corruption & Bribery

[Q&A] Compliance Training for Third Parties Best Practices

By Josh Young Jun 01, 2017

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In a study recently released by Kroll and the Ethisphere Institute, 30 percent of the responding businesses indicated that they believed their risks of bribery and corruption would increase in 2017. And of this group, 40 percent contended that the top reason for this higher risk was third party violations.

Given the recent headlines surrounding Rolls Royce, Airbus, and Zimmer Biomet—both businesses involved with rather public corruption investigations that involved third parties—these sentiments should come as no surprise.

Strategies for Managing Third Parties and Reducing Risks

With third party corruption posing such a tangible threat to most global organizations, we've made sure to discuss this subject in several our blog posts:

We’ve also produced numerous webinars that have taken a more in-depth look at different strategies for reducing third party risks.

During our webinar How to Reduce Third Party Risk With Training, our presenters, compliance experts Michael Volkov, CEO of the Volkov Law Group, LLC, and Farzad Barkhordari, President of Workplace Answers, an EVERFI company, were asked two very insightful questions about third party training. In case you missed the live presentation or haven’t finished watching the recording, we wanted to share the questions and answers here.

Question: What should you do when your third party has its own training?

Michael Volkov: Your business can never spend too much time on training, nor can your third parties. Ask to review their existing program and associated policies to make sure that they conform and are consistent with the culture of your company.

At minimum, you should supplement this established education regimen with training on how and where to report ethics concerns to your company—critical information the third party program will likely be lacking.

Question: How should you respond when your third party has already taken a training course from another company?

Farzad Barkhordari: If the third party is a critical reseller, distributor, or vendor, indicate that they are too integral to your operations and that you will need to review the training they took.

Evaluate the program that they used. And if it sufficiently covers ethics topics and required certifications, you would likely only need to briefly supplement this previous training with additional acknowledgements regarding your company's specific partner code of conduct and policies.


An anti-corruption training program that includes your third parties is one of the most effective strategies for reducing your risk. And in fact, many government agencies routinely consider existing anti-corruption programs during settlement and sentencing phases of investigations.

To explore this subject in more detail and learn how to better protect your reputation and business, watch the complete on-demand recording of this webinar today.

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