Compliance Assurance

Environmental, social and corporate governance (ESG) compliance and anti-corruption compliance are critical risk factors, especially in today’s complex, globalised business environment. Anti-corruption investigations focus on providing comprehensive and reliable verification of compliance with international anti-corruption legislation. Our investigations seek to uncover evidence of fraud, corruption, malpractice or political exposure.

Bearstone has become the trusted provider of compliance monitoring and reporting for international investors, private equity funds, and limited partners. We have seen a steady increase in shareholder activism aimed at sustainability, and the ESG impact of doing business. We develop innovative ESG solutions, define industry best practices, principles and procedures, and establish key performance indicators and development targets.

  Comprehensive and reliable verification of compliance with anti-corruption regulations

  Investigations into evidence of fraud, corruption, malpractice or political exposure

  Investigations conducted according to high ethical and legal standards

  ESG solutions for investors: industry best practice, principles and procedures

  Establishment of key performances indicators and development targets

Bearstone’s compliance assurance service is also aimed at clients seeking to overhaul their existing risk management processes. We offer a phased approach; covering local and regional compliance, FCPA and UK Bribery Act compliance, internal fraud and mismanagement prevention, and background checks for senior employees and key suppliers.

Case Study

Bearstone was hired by a large international manufacturing firm that had recently acquired several production facilities in Europe. The client engaged us to investigate and verify allegations of fraud at one of its subsidiary companies.

The client was aware that a large number of its products were appearing on the black market, and being sold at prices significantly lower than their average retail price. Moreover, the client suspected that senior management was being bribed to inappropriately award contracts to suppliers.

If the allegations of fraud were proven true, the client would need to understand how the wrongdoing had occurred, with Bearstone providing support for subsequent actions, potentially including litigation.

Bearstone began by developing intelligence profiles on a wide list of potential suspects, using open source intelligence (OSINT) and information received from the client. We proceeded with investigative work, including human intelligence-gathering (HUMINT), surveillance, and lawful deception operations, colloquially called “sting operations” to identify the channels via which goods were appearing on the black market.

Regarding the bribery allegations, we similarly used OSINT and the client’s proprietary information to create a long-list of potential suspects. This was followed with a HUMINT comparison of lifestyles versus reported incomes of the suspects, along with their close family members, friends and associates. We identified several substantial discrepancies, and then used asset-tracing methods to find out more about the origins of their unexplained wealth. We found that certain senior managers were awarding contracts to their close friends in exchange for large and inappropriate gifts, such as vehicles, expensive vacations, and lavish parties.

The client decided not to take the case to court for reputational reasons, and dealt with the matter internally. Our findings helped the client not only understand what had occurred and how, but moreover to resolve the issue quickly, efficiently and discreetly.