Global Fortune 500 company restores trust, gets back to business after crisis
Working collaboratively with the company’s compliance team, Grant Thornton’s team developed over 190 procedures
Regulatory and criminal charges following an
Independent monitoring and third-party audit services
When a global Fortune 500 company ran afoul of the law a few years ago, it was big news. Criminal charges and serious legal woes followed. The company was also barred from competing for government contracts. The company eventually came to an agreement with regulators and the Department of Justice (DoJ) that it would provide restitution and make certain procedural changes to correct the actions that had landed them in hot water.
The company’s missteps had led to a significant environmental incident. When law enforcement, regulators and the global company came to terms, among other outcomes, the DOJ required reporting by a third party on series of corrective actions the company had implemented. The plea agreement — reached by law enforcement, regulators and the company — resolving criminal charges required that the company take a number of corrective actions, hire independent monitors to review those actions and engage a third-party auditor to ensure it was in compliance with the terms of the agreement. A second agreement with regulators that resolved civil charges and debarment issues also required the use of monitors and third-party validation.
WHAT THE TEAM DID
The company selected Grant Thornton LLP as the third-party auditor to objectively assess compliance with the criminal and civil agreements and report annually for five years. The stakes for the company are high: If Grant Thornton finds a violation, it could lead to additional actions from the DoJ and/or regulators.
Working collaboratively with the company’s compliance team, Grant Thornton’s team developed over 190 procedures, including observation of on-site safety audits, and crisis response and training drills. The team examined documents; critiqued processes; tested controls; interviewed employees; verified company progress made under the plan; and reported the findings to the company, the DoJ and a probation officer.
The Grant Thornton team completed a five-month audit and issued its first report to the DoJ in August 2014, and a second report in 2015. These audits validate the progress reported by the company in complying with the terms of its probation and implementation plan. As a result of the successful audits, the company is able to comply with its agreement and move forward with getting back to business. This necessary step enables the company to rebuild trust, restore investor confidence and move toward a brighter future.