Integrity due diligence

IntegraWatch® & LexisNexis Compliance Screening

 

Our analysts will:

1. Conduct False Positive Analysis to ascertain the accuracy and relevancy of any findings - these include:

• Search and identify key Personal Identifiers
• Identify irrelevant or false matches to focus on entities and individuals related to the report
• Cross-reference all available data from our research (and, if available, from client-provided data)
• Review and access relevant English and local language sources for any further updates.

2. Once all available data has been reviewed and translated, our analysts will provide a summary with the following considerations:
• Impact to the client based on the industry and jurisdiction of the screened entity/ individual
• The client's risk appetite or requirements
• Are any mitigation/ remediation steps required


Our analysts and country experts will conduct highly-targeted English & local language media research, using Open Source Intelligence techniques and will:

1. Conduct False Positive Analysis, including:
• Search and identify key Personal Identifiers
• Identify irrelevant or false matches to focus on entities and individuals related to the report
• Cross-reference all available data from our research (and, if available, from client-provided data)

2. Use targeted English & local language search strings, including:
• Industry-specific key words
• Country-specific key words
• Key words relating to compliance, integrity and business risks
• Open Source functional search strings to identify deleted or hidden posts

3. Use a comprehensive research methodology, including different browsers and search engines:
• Begin with local media sources
• Move out to regional media sources
• End with global sources in English & the local language
• Cross-reference against English & local language findings
• Determine the validity and reliability of the sources to reduce "hearsay" or "fake" information

4. Once all available data has been reviewed and translated, our analysts will provide a summary with the following considerations
• Impact to the client based on the industry and jurisdiction of the screened entity/ individual
• The client's risk appetite or requirements
• Are any mitigation/ remediation steps required

5. In addition, our analysts will also cross-reference findings with other sources (if applicable, against litigation databases, reputational intelligence, questionnaires, and corporate registry information) to determine if there are any bias or censored details - especially in jurisdictions where there are strong government censorship.

English and Local language Media Research


Our analysts will:

1. Reference The Red Flag Group Risk Methodology, or the client-specific risk appetite/ methodology (if available), to ensure relevant risks are detailed within the report

2. If no online databases are available, we will physically go to the relevant courts to research the on-site databases

3. Once we have access to on-site and/ or online databases, we will review English and local language filings and:
• Translate, where applicable, local language filings
• Ascertain the number of legal cases involving the subject entity and/ or key principals
• Overview of the legal case(s)
• The role of the subject entity/ key principal
• The jurisdiction(s)
• Plaintiff(s)
• Defendant(s)
• Status/ judgement

4. Cross reference findings with English and local language media sources if available

5. Summarise the key cases and provide analysis and insight into potential business and integrity risks

Litigation Database Check


From 11+ years of experience in compliance investigations, we have created a list of key questions to help us uncover and identify:

• Overall business reputation in the market
• Allegations/ suggestions of bribery or corruption
• Allegations/ suggestions of anti-competitive behaviour
• Allegations/ suggestions of bid-rigging/ tender impropriety
• Allegations/ suggestions of political connections (including relatives)
• Discrepancies in the information obtained from other sources (such as corporate registry information)

As part of the process, we will:
• Identify the relevant in-house expert on: the country; the legal system; the industry; the local language
• Use on-the-ground sources to research and identify potential sources
• Obtain correct and relevant contact details of the sources
• Conduct the enquiries in the local language where necessary
• Collate, translate, analyse, and summarise the conversations into a succinct and relevant format.

Reputational Intelligence


Our analysts will review the questionnaire on two occasions:

• First review - analysis and identification of possible integrity or business risks in the information contained
• Second review - during our research of the subject entity, and related key principals, we will try to determine if there are discrepancies contained within the questionnaire and the information we uncover during research

We will also reach out to the client immediately, should there be key information missing or if there are serious discrepancies / potential issues during the first review. Our analysts will provide a brief summary of any discrepancies or issues for easy review by the client.

Questionnaire Analysis


Our analysts will review the client-provided compliance documentation and measure these against global standards such as the ISO 370001, and we will determine:

• Effectiveness of the documentation for the company's size, industry, and jurisdictional operations (e.g. does the documentation cover the key risks faced by the company?)
• Relevance of the documentation for the company's size, industry, and jurisdictional operations (e.g. does the documentation cover unnecessary risks which the company will not face?)
• Effective Communication (e.g. is the messaging consistent and easy to understand for every employee?)
• Are country and industry regulatory requirements being met?
• Clear instructions on the correct and ethical manner of one's conduct
• Clear instructions on how to escalate any issues - including whistleblowing
• Documentation which is showing the improvement process

The senior staff members of the Professional Services team will review all related documentation and research findings, before providing a summary of:
• Any items which do not meet expected global compliance standards
• Any items which do not meet expected regional and jurisdictional regulatory requirements
• Whether or not the documentation helps to encourage a culture of compliance
• Whether or not the documentation are simply paper policies.
• Any items which do not meet the client's expectations.

A senior member of the Professional Services team, selected on their country and industry expertise (as well as local language capability), will prepare a list of questions and conduct the interview to determine:

• A suitable range of employees - from junior staff to senior staff members (if a list of interviewees were not provided by the client)
• Their overall knowledge of compliance in the workplace, the industry, and the relevant jurisdictions as per the employee's role in the company
• Their knowledge of the company's compliance program/ framework/ policies
• Their understanding and interpretation of the company's compliance policies
• Suggestions of integrity impropriety.

Compliance Document Review & Compliance Interviews