Provided legal support of an internal anti-corruption investigation

Our lawyers provided legal support during an internal anti-corruption investigation.

The tasks put before the team included: (1) conducting an anti-corruption check of suspected persons and counterparties; (2) preparing for and participating in an interview with current and former employees of the company in order to identify red flags and signs of unethical conduct of employees; (3) conducting forensic research with regard to analysing transactions involving the sale of products in terms of identifying economic abuses committed by employees of the company who were involved in such sales or by its contracting parties; (4) a brief description of the circumstances forming the elements of the ‘corruption articles’ of the Russian Criminal Code, and other actions covered by the concept of ‘corruption', and (5) analysing the possible risks for the company in connection with the situation that emerged.

Based on the outcome of the investigation, our lawyers prepared a legal memo setting out the violations of legislation that had been identified and the persons involved. Further, the client was provided with guidelines for how the company’s anti-corruption compliance system could be improved.