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Catelas 360 Relationship Compliance

Training Gap Analysis PEP lists. Periodic Audits Risk Assessments. Catelas 360 Relationship Compliance. On-boarding & Due Diligence. Rapid Event Response Investigations. Fully Automated, Real-Time Visualization of your entire 3 rd party Operations.

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Catelas 360 Relationship Compliance

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  1. Training Gap Analysis PEP lists Periodic Audits Risk Assessments Catelas 360 Relationship Compliance On-boarding & Due Diligence Rapid Event Response Investigations Fully Automated, Real-Time Visualization of your entire 3rd party Operations

  2. 3rd Party Compliance & Risk Oversight Session I How much risk are you on-boarding with each new partner or acquisition?

  3. Session I: Agenda Panel Introductions • Thomas Fox, Principal, tomfoxlaw.com • Martha Durcan, Chief Compliance Officer, Parametric Technology CorporationFCPA & UK Bribery Act • Eddie Cogan, Founder & CEO, Catelas, Inc. • Panel Debate & Discussion • What risks exist, when you do business overseas? • What risks should you worry about with each new agent/partner/acquisition? • How to you better understand your risk and measure your risk exposure? • If a partner is high risk what options do you have? • Can technology help? What tech is available today? • How do you ensure you are prepared should you meet the DOJ / SEC? • Questions • Email them to me at eddie.cogan@catelas.com • Or simply use the chat facility on the webinar.

  4. 2012 Enforcement ActionsKey Take-Aways • Morgan Stanley-compliance programs do receive credit • Pfizer – New “enhanced” compliance requirements and due diligence in the merger and acquisition context • Tyco-Non-Prosecution Agreement for repeat Offender • Opinion Release 12-01-how does your due diligence affect your use of agents?

  5. Martha DurcanChief Compliance Officer October 31, 2012

  6. Focus on Ethics and Compliance • Compliance assessment conducted by third party • Charter of PTC’s Board of Directors Governance Committee expanded to include compliance monitoring • Dedicated Compliance Group established • Chief Compliance Officer appointed • A key focus area is Anti-Corruption • New partner on-boarding process implemented • Catelas compliance software purchased to automatically inventory 3rd party relationships, uncover relationship history and to conduct internal investigations

  7. Enhanced Partner Assessment Process There are five key elements of our partner assessment process. • Partner Identification and Business Justification • There must be a business justification for each partner that has been approved by the appropriate manager prior to initiating automated partner due diligence • Partner Assessment – Due Diligence • Partner due diligence process is automated • Partner Engagement • Each partner signs a contract with PTC containing enhanced anti-bribery provisions • PTC’s Anti-bribery Policy is delivered to each partner with the contract signed by PTC • Partner Training • Anti-bribery training will be provided to each partner • The type of training received will be partner-specific based on perceived risk • On-Going Monitoring • Re-assessment at contract renewal and sooner based on deal and region-specific factors PTC CONFIDENTIAL

  8. Partner On-Boarding: Key Challenges and Benefits Challenges • Partner Review in Emerging Geographies • Overcoming challenges presented by different cultures, language, time zones • Distinguishing the true risk profile of a partner • Evaluating the Inherent risks (industry, country) versus partner specific risks (type of partner, target customers of partner) • Due Diligence on Partners with High Risk Scores • Determining when and how much due diligence is adequate Benefits • Increased visibility (not just transparency) into partner relationships • Broader awareness of compliance risks internally and externally • Centralized system of record

  9. Discussion Questions • Red Flags • Do they differ by region? • Examples of red flags that have lead to rejection of high risk partners • Commonly missed items? • Partner Training • Is on-line training effective? • Partner Audits • Are they being done? • How frequently? • Process tips? • Driving Behavioral Change Throughout the Organization • Effective tools

  10. Compliance Burden Compliance must clearly communicate, demonstrate and display the effectiveness of Compliance Programs that combat these risks: • Anti-Trust , anti-competitive business practices and Cartel • FCPA & UK Bribery Act • Indirect Revenue Recognition (JVs, Resellers, and hybrid 3rd Parties) • Partner On-boarding and Due Diligence • Code of Conduct, Sales and Marketing Policy • Supply Chain risk: vendor kick back, conflicts of interest • Data Theft, Intellectual Property and Privacy • Information Barriers and Employees with access to sensitive data • New and Departing Employees "Demonstrating Compliance Effectiveness is Critical:[Regulators] want proof that the programs are actually working."  - Steve McGraw, from Compliance & Ethics Professional Magazine

  11. Catelas360 – End to End Coverage Compliance Audit Legal HR Compliance Lists Finance CRM Email Log Files • Compliance Database • Risk Scores • Employee training certification • Partner certification & agreements • Company Attributes • (From CRM e.g. Siebel) • Company types: customer, partner, distributer, agent • Published Lists • (From World Compliance etc.) • Global Sanction List • Global PEP List • Global Enforcement List • Global Adverse Media List • Global Foreign Official List • Financial Data • (From Finance database) • Total value of partner business • Lists of transaction with partner • Employee / Contractor Attributes • (From Contact / HR database e.g. PeopleSoft) • Role: sales, finance, logistics • Responsibility: VP, Dir, Mgr • Location: Beijing, China • Contact details: email, telephone

  12. 3rd Party Transparency & Control Partners grouped by Region & Relationship Strength Every partner, globally, automatically ranked View Relationship History: What is being said? What work are they doing? Who is key? In your company ? At the partner?

  13. Policy Enforcement & Monitoring Rules focusing on specific behaviors Policies focusing on specific risks Results captured for Review with severity level Risk broken down by time periods of interest Advanced Analytics on identified risk

  14. Litigation Investigations Internal Investigations WITHOUT COLLECTING EMAILS Quickly identify the most relevant custodians based on their relationships Only collect what's relevant. The key relationships lead us to the most relevant keyword-based documents Deliverables: Impact Report within a single day • Identification: Identify key players before collection • Intelligent Collection: of communications between key people • Priority Review of most relevant (< 1%) data within 1st day • Uncover ‘hot docs ’ for senior review within 1st day • Providing counsel with key strategic information about a matter, earlier enabling conflict resolution, better negotiations etc..

  15. Topic 1 The on-boarding process • What are the risks? • Where should you focus?

  16. Poll Question 1 – with Results • How mature is your Compliance program? • <pick one answer> • We have policy and procedures. Employees sign up to these • We have a repeatable on-boarding process • We monitor for risk with annual audits & interviews • We monitor continuously - are looking to change behavior

  17. Topic 2 The on-boarding process • How do you uncover risks? • How do you measure these risks • What do you do about this risk?

  18. Poll Question 2 – with Results • Do you see technology as an essential component of the Compliance function? • <pick multiple answers> • No. We believe our on-boarding process is sufficient • Yes for Financial Transaction Monitoring • Yes for automating and documenting the on-boarding process • Yes for understanding people, relationships and history • Yes - all the above are important

  19. Topic 3 The on-boarding process • How do you prevent risk in the fist place? • Should you monitor for ‘bad actors’?

  20. Topic 4 The on-boarding process • How important is documentation? • What kind of audit trail should you preserve?

  21. Poll Question 3 • Which part of the puzzle is your current focus? • <pick one answer> • Building out a good on-boarding process • Risk Monitoring - understand risk across existing portfolio • Risk Prevention - Training, enforcement, incentives, behavior • Documentation - ensuring a seamless audit trail

  22. Session II Your on-boarding process works, so now what?

  23. Session III Event Response & Remediation when bad things happen, what should you do?

  24. Real Time Control Reduce Costs Catelas 360 Relationship Compliance Respond to events Fast Puts Compliance in Control Low cost, deep visibility from HQ For Legal, Compliance & Security

  25. Thank You Eddie Cogan 617 407 2967 eddie.cogan@catelas.com www.catelas.com

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