Regulations such as the Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and the Dodd Frank Wall Street Reform and Consumer Protection Act (specifically Section 1502 on conflict minerals) have compelled companies to extend their compliance and monitoring efforts beyond the four walls of the enterprise and into the far reaches of their vast and global supply chains. No longer can an organization be ignorant if a downstream supplier is found to be noncompliant with a regulation or company policy. Ultimately, the blame—and any financial, brand, and reputation loss—lies with the company who has the relationship with the supplier, or the suppliers’ suppliers.
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