Managing the Supply Chain

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1 Managing the Supply Chain SCCE Regional Compliance & Ethics Conference Houston, TX November 5, 2010 Speakers Carolyn Egbert Senior Executive Vice President Compliance & Corporate Responsibility Solvay North America LLC Houston, TX Harry Britt Manager, Ethics & Compliance Corporation Houston, TX 1

2 Agenda Third Party reliance Who are third parties Third party risk exposure Managing, Mitigating Third Party Risk Red Flags Interface with suppliers / vendors Recent issue Working with suppliers & Supply Chain Management Solvay Solvay North America, LLC, the North American subsidiary of Solvay SA An international plastics and chemicals company headquartered in Brussels, Belgium with operations in more than 50 countries throughout Europe, North America, South America and Asia- Pacific Solvay introduced its Group Code of Conduct in 2006, setting forth uniform standards of behavior applicable to all employees globally 2

3 Third Parties Third Party Reliance Most companies are dependent upon third parties, e.g., suppliers, contract employees, agents, to conduct business. Businesses are particularly dependent upon third parties to create or expand their global markets. Joint ventures are becoming more common for financial reasons or because they are a condition for doing business in a particular country. In the past, utilizing third parties often meant reducing risks and responsibilities. Today, third party arrangements exposes companies to greater legal risks and damage to reputation. 3

4 Who are Third Parties? Third Party Types: Suppliers, Vendors Distributors, Resellers Contractors, Subcontractors, Licensees Temporary Services Agents, Sales Representatives, Marketing Intermediaries Consultants (Legal, Financial, HSE, Strategic Business, Regulatory Experts, etc.) Advisory Services, Industry Experts Joint Venture Partners Third Party Risk Exposure Because there are many types of third party relationships, the legal and reputational risk exposure can vary widely. Examples of risk exposure: Supplier of your goods violates child labor laws; Contract manufacturer substitutes toxic fillers for ingredients; Your agent inappropriately entertains government officials; Your distributor sells product to a legally prohibited market; Marketing consultant misuses customers private data; or Lobbyist bribes government official. 4

5 Managing / Mitigating Third Party Risk Definition of an effective ethics and compliance program under U.S. Sentencing Guidelines encourage companies to establish effective third party business standards. Caution: imposing ethics and compliance requirements carries legal risks, e.g., imputing third-party acts to the company, third party beneficiary rights. Many companies mitigate these risks by extending features of their ethics and compliance programs. Managing / Mitigating Third Party Risk (cont d) Conduct Risk Assessment U.S. Sentencing Guidelines suggest using three key factors in assessments: Nature and seriousness of potential misconduct to which the relationship could give rise Likelihood that such conduct could occur because of the nature of the relationship or the third party s business; and, The third party s prior history Identify and weigh corruption index assigned to prospective business location (Transparency International Corruption Perceptions Index) Conduct due diligence to identify levels of risk 5

6 Managing / Mitigating Third Party Risk (cont d) Provide training to ensure third party s knowledge of company s ethics and compliance standards. Ensure that third party contracts include terms that require compliance obligations and audit rights and right to contract termination for failure to perform obligations. Provide means for third party to report ethics and compliance concerns, e.g., Helpline, web reporting. Third party code of conduct. Ensure staff oversight Be vigilant in spotting red flags Red Flags U.S. Department of Justice Guidelines: Unusual payment patterns or financial arrangements History of corruption in the country Refusal to certify compliance Unusually high commissions Lack of transparency in expenses and records Apparent lack of qualifications or resources Third party recommended by a foreign official 6

7 Red Flags (cont d) Other red flags may include: Agency fees requested in cash Indication of facilitating payments Multiple agents for same scope of work Political contributions by agent Incomplete or inaccurate information in disclosures Request for payments to third party or third country Ethics & Compliance in Your Supply Chain 7

8 North America s premier natural gas pipeline system Corp. Pipeline System Mojave Pipeline Colorado Interstate Gas Wyoming Interstate Cheyenne Plains Pipeline Tennessee Gas Pipeline Natural Gas Elba Island LNG Southern Natural Gas Florida Gas Transmission 8

9 One of North America s largest independent natural gas producers Corp. Exploration & Production Egypt N I L E D E L T A W E S T E R N E S E R T D S I N A I G U L F O F S U E Z Brazil 9

10 Standards for Service & Material Providers 19 Ethics & Compliance Office Located in Houston Responsible for Ethics & Compliance program Available to help others (including suppliers) make appropriate decisions Answer questions Provide advice on issues Respond to possible violations 20 10

11 Code of Business Conduct Based on core values Spells out system for employee conduct Applies to all employees globally Issued to all employees and non-employee board members Reminds employees of high standards expected 21 Encourage Suppliers to Achieve High Standards Communicate expectations to suppliers Expect employees to act in accordance with the highest ethical and legal standards Also expect suppliers / vendors to interact with the company in a manner consistent with our Code of Conduct and our Values Expect business decisions made on company s behalf to be in the best interest of the company 11

12 Standards for Service & Material Providers Brochure describes El Paso's minimum requirements of its providers Want suppliers to be aware of s expectations 23 EP Standards for Service & Material Providers Conflicts of interest Compliance with laws and regulations Fair competition and antitrust Insider trading Transacting international business Safety and environmental Employment practices Prohibited items including drugs, alcohol and weapons Gifts and entertainment Accuracy of business records Confidential information and trade secrets Use of electronic media Federal Energy Regulatory Commission (FERC) standards of conduct 12

13 Standard Contract Language Company Handbooks. Contractor acknowledges that it has received, reviewed and is familiar with the Company Handbooks, including the Business Ethics Handbook. In addition to its other obligations under this Agreement, Contractor shall require compliance with the Company Handbooks by Contractor and its employees, agents, representatives, invitees, licensee and Subcontractors, and any other persons performing Work under Contractor s control. Supplier Personal Responsibility Work according to s core values and ethical principles Read s Standards for Service & Material Providers Conduct themselves in manner beyond reproach Bring concerns and issues forward promptly 26 13

14 Contact Options for Suppliers Confidential and anonymous toll-free telephone number Direct telephone number address Fax number Intranet form Regular mail address Walk-in 27 Working with Suppliers & Supply Chain Management to Address an Issue 14

15 Anonymous Allegation EP employee had conflict of interest with local suppliers / vendors Corporate Audit investigated and confirmed the allegation Employee was terminated Supply Chain Management Actions Four suppliers placed on probation by s Supply Chain Management (SCM) & local management SCM suspended suppliers from s approved vendor list Pending action by suppliers to implement some form of ethics and compliance program for their own employees 15

16 Ethics & Compliance Office Coordinated with Supply Chain Management Provided suppliers: Checklist / Federal Sentencing Guidelines : Standards and procedures (code) Governing body to maintain oversight Background checks Communication / training Helpline phone system Enforcement / disciplinary measures Ethics & Compliance Office Provided suppliers (continued): List of resources: The Conference Board Compliance & Ethics Leadership Council Ethics & Compliance Officer Association training sources consultants Helpline vendors etc. 16

17 Ethics & Compliance Office Suppliers submitted draft codes / employee handbooks to for review / comment Ethics & Compliance Office: reviewed / evaluated supplier materials met with suppliers and SCM to discuss / evaluate steps taken to develop materials, training, etc Coordinated with SCM on when to reinstate suppliers Established periodic program reviews and site visits by SCM, Ethics Office, management Comments by Suppliers Each of these contractors told SCM they were grateful for the development of these ethics and compliance programs Stated this is something they should have done long ago Could clearly see the value and credibility it added to their company 17

18 Where Do We Go From Here Where Do We Go From Here Supplier relationships can pose significant risk / exposure Initiate / continue focus with key suppliers Try to mitigate risks posed by suppliers / third parties Communicate intent to operate with integrity Develop relationships with suppliers that share similar values and conduct business in an ethical manner 18

19 Questions 19

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