Welcome back to the podcast, Bride, Swindle, or Steal. I'm Alexandra Ragi, and today we're going to have a conversation about anti-bribery due diligence on third-party intermediaries. I'm going to list red flags and ask my guests to weigh the relevance of

each of them with me. My intrepid guest for this is Carolyn Lindsay, head of ethics and

compliance at Tate and Lyle in London. Prior to joining Tate and Lyle, Carolyn was at NBC Universal,

and prior to that, she spent five years as my colleague at Trace. Thank you for joining me,

Carolyn. Thank you, joining me, Carolyn.

Thank you, Alexandra.

I've done something like this at some in-house events,

and it amazes me that everyone in the room will have a different view of risk and will weigh these red flags differently.

But that really just reinforces the idea that due diligence is incredibly judgment-laden.

We're going to imagine that you work for a company that manufactures heavy equipment.

Your business development team wants to retain a sales agent in Thailand, his name is Tan,

to sell that equipment to the Thai government, both directly and through state-owned entities.

He'll be paid on a commission basis.

Now, I know some people listening will say,

our companies don't permit contingent compensation schemes,

but just assume that this is typical

for this industry and this region.

Your in-house team has run your usual higher risk

due diligence report in light of the contingent compensation,

the market, and the government customer.

So you're reading this due diligence report for the first time, and you know that your

business development team really wants Tan to work for them.

...