III Overcoming Resistance/Inertia

So your company has just decided to expand overseas, or at least sell its products or services outside the U.S.  Or maybe you’ve seen some news articles about companies in trouble under the Foreign Corrupt Practices Act - or you just started worrying about it.  So you checked the TI-USA web site and here we are - just loaded with information and resources.  But how to get started?  How to actually do it, especially in a small-to-medium sized company that “hasn’t had a problem”?  Herewith, a few suggestions:

      scout out what already exists and build on that; every company has something, if only audited financial statements.

      begin risk assessment at the lowest levels of the organization by asking questions, not lecturing

      take it slowly:  build consensus function by function, start with Finance, audit, Environment Health Safety, Human Resources, Risk Management, then Operating Managers.

      “lobby” by circulating newspaper articles, get on the sales/marketing meeting agendas, place items in the company newsletter.

      once awareness has been heightened, propose a few low-impact, low-cost basics at the function/plant levels in areas where the need is greatest.

      learn your business processes, who does what and graft pieces of the program into the business structure.

      present the program to upper management in terms of protecting the company and extending its core values.

      at this point few, if any, additional resources should be needed to formalize the program and obtain CEO and Board of Directors’ approval.

Now that all the approvals have been obtained, you might want to review the Ethics Program Overview.  For more background information, see Bibliography of General Sources.