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Business ethics and anti-corruption


Meet the team

Our China business ethics and anti-corruption (BEAC) team advises multinationals and financial institutions on a wide range of BEAC issues in the People’s Republic of China. We provide tailored and strategic advice to clients throughout our key industry sectors: financial institutions; energy; infrastructure, mining and commodities; transport; technology and innovation; and life sciences and healthcare.

The team has excellent knowledge of the BEAC risks encountered in China by foreign clients, such as:

  • procurement/sourcing risks
  • extortion
  • commercial bribery
  • gifts, entertainment and hospitality
  • relationship with third parties
  • internal corruption.

Working closely with our BEAC colleagues throughout Europe, the United States, Canada, Latin America, Asia, Australia, Africa and the Middle East, our team regularly advises clients to meet international compliance needs across a wide range of issues.

We deliver

  • Bespoke advice and tailored policies, procedures and guidelines to manage and reduce the risk posed by corrupt activity when operating in mainland China.
  • Assistance with internal investigations and anti-corruption audits, including document review, employee interviews, financial systems review.
  • Due diligence of target companies and intermediaries in the context of mergers and acquisitions.
  • Strategic advice in the context of regulatory investigations and coordination of other third parties such as forensic accountants and security companies.
  • Training of employees and company management on BEAC issues, including assistance with setting-up e-learning programmes.

Our areas of work include

  • anti-bribery and corruption
  • anti-money laundering
  • data protection
  • employment
  • fraud.

Our recent work

  • Advising a European manufacturer of luxury automobiles on a comprehensive legal audit of their PRC activities, carrying interviews with management in all departments (including sales, HR, finance, IT, legal, general admin, procurement, research and development, strategy, after-sales, franchising), conducting site visits and reviewing sales and expenses documentation.
  • Advising a multinational pharmaceutical company on its third party review procedures and preparation of relevant documentation tools and advising on compliance issues related to the proposed Phase IV drug trial to be launched in China.
  • Advising a global engineering group on the design and implementation of their compliance program in the PRC, including carrying interviews with sales force, reviewing gifts and entertainment policies and processes, reviewing relationships with third parties, and carrying an investigation into whistleblower claims related to corruption.
  • Advising a Malaysian water company on the drafting and implementation of a gift and entertainment policy in the PRC, including training of management.
  • Advising a US-listed mining company on drafting and implementation of PRC compliance policy, including training of PRC employees.
  • Advising a Canadian footwear manufacturer on their PRC compliance and anti-bribery policy.
  • Advising a US defense contractor on the localisation of their compliance handbook.
  • Advising a Swiss financial institution on corruption/anti-bribery advice regarding organisation of study travel for PRC officials.
  • Advising an Australian engineering group on its PRC compliance policy.