ANTI-CORRUPTION SURVEY 2014
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1 TO BE PUBLISHED WITH THE JUNE 2014 ISSUE OF IFLR INDUSTRY POLL SERIES MANAGING CROSS-BORDER RISK FOR IN-HOUSE COUNSEL
2 Anti-corruption Guest edited by A guide to navigating anti-corruption laws in unfamiliar markets After years of the US Foreign Corrupt Practices Act as one of the only heavily enforced extraterritorial anti-corruption regulations, 2013 saw jurisdictions globally passing and enforcing new regimes. The increasing focus on anti-corruption has prompted a new focus on compliance measures, such as training programmes and whistleblower processes. But it has also raised questions about anti-corruption laws in emerging markets, with one of 2013 s biggest developments seeing China s anti-corruption regulator enforcing against bribery by multinational pharmaceutical company GSK. So companies managing anti-corruption risks now need to understand regulations in unfamiliar jurisdictions; compliance systems and processes must be consistent with local regulatory requirements. IFLR s inaugural Anti-Corruption Survey will provide clarification on best practice for complying with anti-corruption regulations. Conducted on a global basis, it will offer insight into idiosyncrasies in current practice in the markets that matter most. Guest edited by Debevoise & Plimpton partner Andrew Levine, the results will be published as a dedicated supplement with the June issue of IFLR. The guide will provide readers with: Jurisdictional colour coded rating At-a-glance overview of each featured jurisdiction Highlighting significant local implementation factors Facilitating an easy comparison of territories Contributions from local law experts Concise guidance on local law See overleaf for your invitation Expert analysis from leading international practitioners See right for confirmed contributors Andrew Levine Debevoise & Plimpton, US Confirmed contributors Matthew Getz Debevoise & Plimpton UK Philip Rohlik Debevoise & Plimpton Hong Kong Srirak Pilpat Transparency International Asia-Pacific Regional director Stephen Zimmerman World Bank Integrity division Director of operations Cecilia Malmström European Commission Commissioner of Home Affairs PREVIOUS IFLR SURVEY CONTRIBUTORS
3 How to get involved Given your local expertise, we would like to invite your firm to participate in the survey on a sponsorship basis, and demonstrate how you can assist international corporates and financial institutions in understanding anti-corruption and bribery regulation that impact your jurisdiction. We would like to offer you the following sponsorship package: Exclusive opportunity to respond to the survey for your jurisdiction all opportunities are offered to local experts on a first-come, first-served basis Publication of your firm s responses in a dedicated results supplement up to 750 words published and distributed with the June issue of IFLR Publication of your firm s response on an online interactive map please visit for more information Up to two senior lawyer profiles 150-word bios, including headshots & contact details. Displayed alongside your survey responses 10 print copies of the print supplement for internal and client distribution purposes High resolution PDF of the published results with distribution rights to existing and potential clients Promotional activities via IFLR s print, online and social media channels see overleaf for details Cost of participation To discuss sponsorship opportunities please contact a member of our sales team. All opportunities are offered on a strictly first-come, first-served basis. To discuss sponsorship opportunities please contact At a glance Anti-corruption survey, conducted on global basis, over a one-month period Guest edited by Andrew Levine, Debevoise & Plimpton, US Confirmed contributors Debevoise & Plimpton, EC, Transparency International, World Bank Provides financial institutions and corporates with a clear understanding of recent developments impacting anticorruption and bribery Results and analysis published on a NEW online interactive map: Results and analysis published in a dedicated supplement with the June issue of IFLR Features at-a-glance overview; guidance on local law; and international analysis Exclusive sponsorship opportunities offered to firms recommended to IFLR by our international partners EUROPE AND NORTH AMERICA Liam Sharkey Tel: +44 (0) lsharkey@iflr.com LATIN AMERICA Roberto Miranda Tel: +44 (0) rmiranda@iflr.com ASIA, MIDDLE EAST AND AFRICA Denny Squibb Tel: denny.squibb@iflrasia.com RESERVATION DEADLINE: APRIL 18 COPY DEADLINE: MAY 2 Packages include: Exclusive right to respond to the survey for your jurisdiction Up to two senior lawyer profiles displayed alongside your responses 10 print copies of the supplement High resolution PDF of the published results with distribution rights Promotional activities via IFLR s print, online and social media channels See overleaf for more information.
4 Promotional activities All survey results will be: Published on a new online interactive map: Iflr.com has >22,000 2 unique monthly visitors Published in print with the June issue of IFLR magazine IFLR has a loyal readership of at least 5,302 1 per print issue Promoted in IFLR s weekly e-newsletter IFLR s e-newsletter has >18,000 3 subscribers Promoted to IFLR s LinkedIn network IFLR has >4,000 LinkedIn group members The survey will also be promoted electronically to delegates who registered for the following events: IFLR Asia M&A Forum, February 2013 IFLR Africa Forum, May 2013 IFLR India Outbound Forum, July 2013 IFLR Asia Capital Markets Forum, November 2012 IFLR European In-House Counsel Summit, January 2013 IFLR European Capital Markets Forum, April 2013 (See appendix 2 on pages 6-7 for a selection of IFLR s influential magazine and e-newsletter subscribers.) Print and online exposure Print reach IFLR magazine has a loyal readership of at least 5,302 1, per print issue IFLR.com monthly usage statistics Average unique visitors >22,000 2 / month Average page views >67,000 2 / month Social media IFLR s e-newsletter has >18,000 3 subscribers IFLR has >4,000 LinkedIn group members SUBSCRIBERS By company type (including print subscribers and free weekly subscribers 4 ) 38.3% Corporate / financial / government institution 46.1% Law firm 8.1% Academic institution PRINT ONLINE NEWSLETTER APP 7.4% Other FOOTNOTES 1. The readership rate based upon a survey conducted in Oct 2013, has been independently audited by IPSOS MORI, the international media consultancy. 2. Source: Webtrends Oct 12-Nov Figures based on IFLR weekly campaign sent on 6th December A combined analysis of IFLR print subscriber file and 10% of IFLRís weekly distribution extrapolated across 18,000 recipients.
5 Appendix 1: How it works Responding to the survey IFLR will provide you with: Survey questions Clear survey guidelines Templated responses that can be adapted to your jurisdiction available on request You will be required to: Respond to the survey questions Select the appropriate rating according to our colour coding system (*) Adapt the templated responses to your jurisdiction Provide concise guidance on local law where applicable Submit no more than 750 words in total We anticipate that this should take no longer than one hour to complete. Survey methodology, guidelines and timeline IFLR will: Distribute the survey in early mid-april Collate all results in early May Analyse and present the responses Categorise the responses according to a colour coding system (*) Publish all results (including an at a glance table) with the June issue of IFLR (*) Colour coding system Based on the responses, legal systems in each jurisdiction will be rated on a spectrum that ranges from liberalism to strict control. This scale is neutral in terms of legal values. It does not constitute legal advice nor measure whether or not a particular approach is justifiable or reasonable. The ratings are: RED Indicates a regime in which antibribery laws and their enforcement are generally only rudimentary. AMBER Indicates a regime in which there are moderately broad and sometimes enforced anti-bribery laws. GREEN Indicates a regime in which there are robust and vigorously enforced transnational anti-bribery laws. Designing the survey and selecting respondents IFLR has worked closely with Debevoise & Plimpton to identify: Key jurisdictions across Europe, North America and Asia-Pacific Local expert firms operating within those jurisdictions Key areas focus on: Legal landscape Potential penalties Investigation Adjudication Key questions around these areas with templated responses A colour coding system for responses (*) Marketing and promotional activity IFLR will conduct the promotional activities detailed on page 4.
6 Appendix 2: selected IFLR subscribers When your firm partners with IFLR you have the opportunity to influence decision makers who subscribe to IFLR and who receive the free weekly . These are the leading buyers of legal services in Banking, Capital Markets, M&A, and Financial Regulation. They include: ABN Amro Accenture Addleshaw Goddard African Development Bank Air China Southwest Company Akin Gump LLP Allen & Gledhill Allen & Overy LLP American Express Anderson Mori & Tomotsune Anglo American Plc Anheuser Busch ANZ Bank Aon Asset Management Aon Risk Services Arab Petroleum Investments Corporation Arthur Cox Company Ashurst LLP Asia Commercial Bank Asia Mezzanine Capital Group Asia Pacific Mining Ltd Asian Development Bank Association of Financial Markets Australian & New Zealand Bank Australian Treasury Aviva Ltd AXA Bahamas Financial Services Board Baker & Mckenzie Baker Botts Banca D Italia Cons Legale Banco Central Argentino Banco Central De Chile Banco Central De La Republica Banco Central De Reservas Del Peru Banco De Espana Bank Austria Creditanstalt Bank of Albania Bank of America Merrill Lynch Bank of England Bank of Ireland Group Bank of Japan Bank of Korea Bank of Mongolia Bank of Montreal Bank of New York Mellon Bank of Uganda Banque Ouest Africaine De Barclays Capital Barclays Bank Plc Berwin Leighton Paisner Bhp Billiton Limited Binder Grosswang Rechtsanwalte Bingham Mccutchen LLP Blackrock BNP Paribas Board of Governors Fed Reserve BP British Land Capgemini Capita Insurance Services Capital Markets Board of Turkey Capital One Cb Equity Partners Gmbh Central Bank of Trinidad & Tobaga Chadbourne & Parke Citigroup Cleary Gottlieb Steen Hamilton Clifford Chance Clyde & Co LLP Cms Cameron Mckenna LLP Codetel A Verizon Company Cogent Partners Commerzbank Ag Commodity Futures Trading Commission Commonwealth Bank Control Risks Conyers Dill & Pearman Pte Ltd Cravath Swaine & Moore LLP Credit Agricole Suisse Sa Credit Lyonnais Credit Suisse Cuba Central Banco Daewoo Securities Daiwa Securities Smbc Europe Danish Bankers Association Davis Polk & Wardwell Debevoise & Plimpton Deloitte LLP Deutsche Bank DLA Piper LLP US Dubai Islamic Bank Duke Law School Easyjet Airline Co Ltd Edward Nathan Sonnenbergs Edwards Angell Palmer & Dodge EMI Ltd Ernst & Young European Bank For Reconstruction European Central Bank European Commission European Parliament Eversheds LLP Exxonmobil Federal Reserve Bank of Ny Federation Bancaire Francaise Financial Services Authority Fitch Ratings Fraser Milner Casgrain LLP Freshfields Fried Frank Harris Shriver Fulbright & Jaworski LLP GE Capital Gibson Dunn & Crutcher LLP Gide Lotrette Nouel Aarpi Goldman Sachs Grant Thornton LLP Gulf International Bank Harneys Hengeler Mueller Herbert Smith LLP
7 Hogan Lovells Intl LLP Honeywell Hong Kong Exchange & Clearing HSBC Ltd Hutchison Whampoa Limited Hyder Consulting Hydro Tasmania Hyundai Motor Finance Company IBM ICAP Indian Oil Corp Ltd Infosys Technologies Limited Ing Bank Inter American Dev Bank International Capital Markets Association International Monetary Fund Irish Stock Exchange Islamic Development Bank Istanbul Gold Exchange J & A Garrigues SLP J P Morgan John Deere Credit Jones Day K&L Gates LLP Kim Chang & Lee King & Spalding Intl LLP Kirkland & Ellis Inter LLP Korea University KPMG Latham & Watkins LLP Lazard Freres Lenz & Staehelin London School of Economics Loyens & Loeff Macfarlanes LLP Macquarie International Ltd Mannheimer Swartling Advokatby Maples And Calder Maritime & Port Authority of Singapore Mayer Brown International LLP Mcdermott Will & Emery LLP Mercedes Benz Mercer Capital Merrill Lynch Microsoft Corporation Milbank Tweed Hadley & Mccloy Ministry of Finance Finland Ministry of Finance Mexico Ministry of Finance Slovenia Mitsubishi UFJ Secs Intl Plc Mizuho Corporate Bank Ltd Monetary Authority Singapore Morgan Lewis Bockius LLP Morgan Stanley Morrison & Foerster LLP National Bank of Belgium National Grid National Trust Holding Company Natixis Nauta Dutilh Nestle Newedge News Corporation Nomura International HK Ltd Nordea Bank Ab (Publ) Norton Rose LLP Novartis International AG Nyse Euronext Oaktree Capital Mgmt LLC Ogier O Melveny & Myers LLP Ontario Securities Commission Opec Fund For Int Development Oracle Corp SA Orrick Herrington & Sutcliffe Oxford University Paul Hastings Paul Weiss Rifkind Petrobras Pillsbury Winthrop Shaw Pinsent Masons Pricewaterhousecoopers Proskauer Rose Prudential Rabobank International RBS Reed Elsevier NV Reed Smith LLP Resolution Asset Management Ropes & Gray LLP Royal Bank of Canada Salans Samsonite Corporation Samsung Santander Global Banking Saxa Equity Partners Securities And Futures Commission Shearman & Sterling LLP Shell Shepherd And Wedderburn LLP Sidley Austin Siemens AG Simmons & Simmons Simpson Thacher & Bartlett LLP Skadden Arps Slate Meagher Slaughter And May Smbc Nikko Capital Markets Squire Sanders & Dempsey Stagecoach Holdings Plc Standard Bank Stanford Law School Stephenson Harwood Stikeman Elliott Sullivan & Cromwell Svenska Handelsbanken AB Swiss Reinsurance Company The Blackstone Group LLP The Central Bank of China UBS Unilever Uniqlo University of Hong Kong US Department of Treasury Vinson & Elkins L.L.P. Visa Europe Volkswagen Volvo Treasury Ab Wachovia Bank Waitrose Walmart Stores Weil Gotshal & Manges LLP White & Case LLP Wilmer Hale Law Firm Wong Partnership LLP World Bank Yale University Zambia Competition Commission Zurich Financial Services Source: Active subscriber list for November 2013 print or weekly subscribers. Please note that future circulation lists will vary.
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