| | DECEMBER 201819CIOReviewThe Old Model ­ Compliance Information "Push"Imagine a salesperson from your organization is traveling to a country in Asia to meet with government officials about a public tender. The officials suggest a local restaurant for dinner. The employee vaguely remembers a policy she saw during her new hire orientation three years ago that mentioned something about entertaining government officials. The policy says she may not entertain government officials during a public tender but she doesn't remember this. It's the middle of the night back at the home office; no one is checking email and she doesn't know anyone locally to ask for help. She decides to go ahead with dinner and orders blindly off the menu as she can't read the local language and is unsure of how much things cost. The officials order many bottles of wine and the local specialty liquor. When the bill finally arrives, it is in local currency and she is unsure of how much it is. Because she can't remember the company policy, she decides to play it "safe" and pays the bill with her personal credit card with a plan to have the company reimburse her later (a potential books and records violation under the FCPA). The day after the outing, your company is awarded a large contract from the government entity worth millions of dollars. The company congratulates the employee on her successful trip. A week later, a competitor files a protest alleging your company won the tender only as a result of having "wined and dined" the government officials, a potential bribery offense posing tens, or even hundreds of millions of dollars in potential fine exposure under both local and U.S. law.This type of situation happens with surprising frequency. Employees don't have access to the information they need when they actually need it. They find applying a policy or procedure in a real-world situation to be much harder than it looks; especially when they last saw the applicable policy months or even years ago.THE ROLE OF TECHNOLOGY IN A"JUST IN TIME" MODEL FOR CORPORATE COMPLIANCEBy Gwendolyn Lee Hassan, Managing Counsel ­ Global Compliance & Ethics, CNH Industrial
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