Global Widget Co. recently acquired a local company in Pakistan

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Global Widget Co. recently acquired a local company in Pakistan, a country with a high level of state involvement in the economy and a history of corruption. Before purchasing the company, Global Widget hired a major international law firm to conduct a due diligence review and uncover any potential violations of global anti-corruption laws. When the review came back free of problems or issues, Global Widget completed its acquisition.

Three years later, Global Widget executives were conducting their first anti-corruption compliance training with employees from the Pakistan office. During the training session, Global Widget was alerted by Pakistan-based employees that the distributors the company hires may be bribing local government officials. Global Widget had not conducted a review of the distributors in Pakistan. When it looked into the allegations, it found widespread potential Foreign Corrupt Practices Act and UK Bribery Act violations. What are two weaknesses in the Global Widget anti-corruption compliance program?

a. Global Widget did not include its distributors in Pakistan when it conducted its anti-corruption due diligence and training.

b. the due diligence review should have been conducted exclusively by local counsel in Pakistan because they would be better versed in the country’s culture and laws.

c. Global Widget should have conducted anti-corruption compliance training as soon as possible after acquiring the company in Pakistan.

d. Global Widget failed to reach out directly to government agencies in Pakistan to request information on any history of corrupt payments at the company it was acquiring.

e. a and c

f. c and d

g. a and d

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