Best Practices in FCPA Compliance: Dell


Last week one of our i-Sight clients, Dell, received recognition for their FCPA Compliance Program from the Open Compliance and Ethics Group (OCEG). Dell was granted GRC Capability Design Certification for meeting standards outlined in the OCEG’s “Red Book.” The GRC Capability Certification was designed to recognize company programs addressing areas of risk, including anti-corruption, employment compliance and government contracts. The GRC Capability Certification is administered to companies by the OCEG based on the findings in a qualified third-party report, adhering to the procedures outlined by the OCEG.

In the OCEG press release announcing the award, Gracie Renbarger, Chief Ethics and Compliance Officer for Dell was quoted, stating:

“We are delighted to receive the OCEG certification as it recognizes our most recent efforts, and our overarching goal has been and continues to be centered on ways to most effectively operationalize Dell’s longstanding and unwavering commitment to act legally and ethically in all we do.”

Carole Switzer, President of OCEG stated:

“While not a point in time certification of FCPA compliance, the certification is an acknowledgement that Dell has taken significant, proactive steps to design a program that will enhance its ability to appropriately prevent, detect and react to non-compliance.”

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