Situation

An international mining company became aware of allegations of systemic corruption linked to executives with a local subsidiary and government officials, with potentially significant regulatory consequences for the company in the US and Europe.

Task

Our client wanted an independent assessment of allegations of improprieties relating to operations by its local subsidiary. The client wanted to understand potential exposure to anti-bribery legislation in the US, EU and UK; the risk of negative publicity or a substantial fine; and potential mitigation strategies, as part of an engagement with relevant agencies in the US, EU and UK.

Action

We were able to access a network of sources in central, provincial and local government, industry, local communities and civil society to deliver reporting that helped confirm the client’s concerns in relation to political exposure and alleged irregularities around procurement of services. We were able
to develop a remediation strategy and stress-check implementation and delivery.

Results

Our input helped the client resolve outstanding issues without reputational hazard, adverse publicity or a substantial fine – and to operate more effectively, in compliance with the local regulatory environment and international best practice.