Day 1 - Wednesday, March 13, 2019

8:00
Registration Begins and Welcome Refreshments
9:00
Conference Co-Chairs’ Opening Remarks
9:15

KEYNOTE ADDRESS

Requirements and Expectations of Italy New Anti-Corruption Law
10:15
New Third-Party Risks Affecting Multinationals: Best Practices for Global Risk Assessment & Management
11:15
Morning Networking Refreshments
11:45
The Law No. 179 of 30 November 2017 on Whistleblowing One Year In: An Implementation Demo
12:45
Networking Lunch
2:15
Chief Financial Officer (CFO) Interview
3:00
AFTERNOON BREAKOUT ROUNDTABLES
4:00
Afternoon Networking Refreshments
4:30

INTERNAL INVESTIGATIONS PROTOCOLS

How to Effectively Structure, Scope and Manage the Process from Start to Finish
5:30
End of Day One

Day 2 - Thursday, March 14, 2019

9:00
Conference Co-Chairs’ Opening Remarks, Recap and Audience Participation
9:30
Corporate Governance Models to Protect Directors’ Liability: How to Establish Effective Risk & Compliance Internal Controls and Reporting
10:30

GOVERNMENT INVESTIGATIONS PROTOCOLS

How to Respond to an Investigation Request and Coordinate the Defence Strategy Across Different Jurisdictions
11:30
Morning Networking Refreshments
12:00
OECD INTERVIEW
12:45
Networking Lunch
2:00

COMPLIANCE PROGRAMME BENCHMARKING: POLLING QUESTIONS AND AUDIENCE PARTICIPATION

Senior Compliance Officers Weigh in on the Hottest Button Issues Affecting Anti-Bribery & Compliance Management Systems
3:00

INNOVATIONS IN ABAC COMPLIANCE TRAINING – CASE STUDY

Real-Life Examples of Training Programmes Tailored to Values, Culture for Effective Operational Implementation and Commitment to Compliance
3:30
Morning Networking Refreshments
3:45

DATA PROTECTION & GDPR POST-IMPLEMENTATION?

Common Challenges to Implementing the GDPR, the First Data Breaches and How to Minimize the Risk of an Enforcement Action
4:30

PUBLIC PROCUREMENT WITHIN ANTI-CORRUPTION AND ANTI-MAFIA BOUNDARIES

How to Strengthen Tender Systems and Internal Processes to Control New and Evolving Corruption Risks
5:30
Conference Ends & Closing Remarks

Day 1 - Wednesday, March 13, 2019

8:00
Registration Begins and Welcome Refreshments
9:00
Conference Co-Chairs’ Opening Remarks

Giovanna Barbieri
Chief Compliance Officer
Inalca SpA

Marco Reggiani
General Counsel
Snam

Bruno Cova
Partner
Paul Hastings

9:15

KEYNOTE ADDRESS

Requirements and Expectations of Italy New Anti-Corruption Law

Vittorio Ferraresi
Undersecretary of State
The Ministry of Justice, Italy

10:15
New Third-Party Risks Affecting Multinationals: Best Practices for Global Risk Assessment & Management

Marco Reggiani
General Counsel
Snam

Edoardo Lazzarini
Former Europe & Canada Compliance Initiatives Director
Takeda Pharmaceuticals

  • What tangible improvement companies are doing in due diligence, risk-ranking process to control third party risk
  • How much due diligence is enough: How to know if your approach is truly “risk-based”
  • Considering evolving risks, how organisations conduct corruption risk assessments today
  • Special considerations for vetting investors, partners, agents, distributors, sub-distributors and lower tier supply chain
  • What kinds of information should you seek from a distributor relating to an audit of its distribution network?
  • When performing a routine risk-based audit of your distributors, what to do if your distributor refuses to provide the identity of its sub-distributors
  • When and how much to train third parties
  • The scope of due diligence to perform for an ongoing, existing third-party relationship

11:15
Morning Networking Refreshments
11:45
The Law No. 179 of 30 November 2017 on Whistleblowing One Year In: An Implementation Demo

Isabella Bdoian Gonzalez
Director, Ethics and Compliance, EMEA
Whirlpool Corporation (Italy)

The audience will benefit from a unique opportunity to hear critical updates the implementation of the whistleblowing requirements extended to the private sector. The panel of experts will discuss compliance efforts, implementation challenges and share – through a demo – best practices to take away and to benchmark your whistleblowing system.

12:45
Networking Lunch
2:15
Chief Financial Officer (CFO) Interview
3:00
AFTERNOON BREAKOUT ROUNDTABLES

Alessandra Ferrari
General Counsel
A2A

Carmen Di Marino
Chief Legal Officer
Dompè Farmaceutici Spa

Francesco Bortone
Chief Compliance Officer
Avio Aero

ROUNDTABLE 1

CONFLICT OF INTEREST REAL LIFE STORIES:
Ensuring that the Interest of the Company is Secured and the Risk of Improper Influence of the Decision-Making Process is Reduced

Alessandra Ferrari
General Counsel
A2A

Carmen Di Marino
Chief Legal Officer
Dompè Farmaceutici Spa

  • Conflict of interest vs. corruption and do they matter?
  • Criteria for assessing a conflict of interest
  • How can conflict of interest policies be effective?
    • Role of industry Codes of Conduct and compliance principles
  • Hiring process scenario: How to ensure that the hiring process in general is not unduly influenced by the government, local authorities & communities, trade unions, …
  • Third party scenario: how to handle the situation when an employee’s family member owns the supplier your organisation has hired; How third parties’ legitimate interactions can give the appearance of improper dealings
  • Personal relationship scenario: how to handle personal relationships leading to romance or marriage during business
  • The joint venture scenario: how to establish appropriate business relationship with SOE (State-Owned Enterprises) as joint venture partner and reduce the risk of conflict of interest

ROUNDTABLE 2

ECONOMIC SANCTIONS RISK & COMPLIANCE:
What Every Compliance and Legal Officer Needs to Know about Their Organisation’s Potential Exposure to Sanctions Risks

Francesco Bortone
Chief Compliance Officer
Avio Aero

Join this roundtable for an overview of the most topical and pressing issues relating to Sanctions you must be aware of, including:

  • Industry perspectives on the most pressing sanctions risks confronting the financial and the non-financial community
  • How to conduct an effective risk-based assessment to capture sanction, fraud, AML and other financial crimes
  • Increased and relentless regulatory expectations and enforcement – Sanctions & AML requirements and implications for both the financial and the non-financial industries
  • When you are contractually bound by OFAC compliance provisions from your bank, what does it mean and what are the implications on your compliance programme
  • Guidance on navigating the complex global sanctions ecosystem

4:00
Afternoon Networking Refreshments
4:30

INTERNAL INVESTIGATIONS PROTOCOLS

How to Effectively Structure, Scope and Manage the Process from Start to Finish

  • How to assemble the team, determine the scope and engage different departments while ensuring that there is independence in the process
  • What should be the role of the compliance officer in an internal investigation?
  • Cultural considerations and practical interview techniques to ensure you get the information you are seeking in the jurisdiction where the facts took place
  • How to deal with inconclusive findings and avoid any perceptions of “an unsatisfactory investigation
  • How to communicate with local and foreign authorities regarding a potential violation — what protections are provided to the company?
  • Determining how much you need to spend and how to control the risk of rising costs
  • When to stop: How to know when to conclude the investigation
  • Why some internal investigations do not detect the wrong doing?

5:30
End of Day One

Day 2 - Thursday, March 14, 2019

9:00
Conference Co-Chairs’ Opening Remarks, Recap and Audience Participation

Giovanna Barbieri
Chief Compliance Officer
Inalca SpA

Marco Reggiani
General Counsel
Snam

Bruno Cova
Partner
Paul Hastings

9:30
Corporate Governance Models to Protect Directors’ Liability: How to Establish Effective Risk & Compliance Internal Controls and Reporting

Silvio Cavallo
General Counsel
Pillarstone Italy

Agostino Nuzzolo
General Counsel and Legal Affairs Executive Vice President – Secretary of the Board
Telecom Italia Mobile “TIM”*

  • The challenges related to coordinating 231 models in group of companies
    • The impact of proxies on directors and managers sitting in different Boards across the group
  • Mitigating directors’ liability when sitting on different Boards of different entities of the group
  • Internal audit v. compliance: What is the best structure to prevent and mitigate risks? How best to allocate different risk control functions across the organisation?
  • Information to channel to the Organismo di Vigilanza and how best to ensure it flows
  • Practical experience on the effective supervision of the Organismo di Vigilanza in implementing the 231 model
  • What is the optimum structure, reporting lines to ensure efficiency in the decision-making process?
  • How should an integrated control system look like, considering recent scandals and cases?

 

* Speakers invited

10:30

GOVERNMENT INVESTIGATIONS PROTOCOLS

How to Respond to an Investigation Request and Coordinate the Defence Strategy Across Different Jurisdictions

  • Initial investigative actions at the early stages of the crisis: How to develop a detailed work plan, create credible parameters for the investigation
  • Measuring the severity of the allegation to plan the most effective response strategy
  • How to plan the financial costs of an investigation
  • What is the best preventive document retention policy for building a defence for the company?
  • What rights do you have during the investigation?
  • How to meet disclosure requests, to what degree to disclose? What is enough?
  • When to make a statement, developing a messaging strategy consistent for all audiences and avoiding pitfalls related to external communications
  • Deciding when to retain outside counsel, forensic accountants and how many
  • How to discuss with employees to ask them to cooperate with the interview and investigation
  • What effects the settlement in one jurisdiction trigger in another jurisdiction?
  • The multijurisdictional approach to cross-border proceedings and how to ensure the consistency of the defence

11:30
Morning Networking Refreshments
12:00
OECD INTERVIEW

Nicola Bonucci
Director for Legal Affairs
Organisation for Economic Co-operation and Development

12:45
Networking Lunch
2:00

COMPLIANCE PROGRAMME BENCHMARKING: POLLING QUESTIONS AND AUDIENCE PARTICIPATION

Senior Compliance Officers Weigh in on the Hottest Button Issues Affecting Anti-Bribery & Compliance Management Systems

Palma Scardaccione
D. Lgs 231/01 & Antibribery Expert Compliance & Quality External Affairs
Vodafone Italia SpA

Take the pulse of the audience on how compliance programmes are increasingly evolving to deal with multiple risks. The panel moderator will ask the audience 10 questions specific to compliance programmes, covering areas such as structure, resource allocation, reporting, certification & standards, governance, metrics and related compliance areas including anti-trust compliance. The polling results will be shared in real-time and the panel of experts will provide practical comments.

3:00

INNOVATIONS IN ABAC COMPLIANCE TRAINING – CASE STUDY

Real-Life Examples of Training Programmes Tailored to Values, Culture for Effective Operational Implementation and Commitment to Compliance

  • Identifying the purpose and mission of your compliance programme
  • How to facilitate effective compliance training in your business: what is a suitable structure for you?
  • Demonstrating the value that strong compliance adds to the business including winning more clients
  • How to design programmes that meet the needs of both individuals across different function

Practical examples of successful compliance training to exchange during the roundtable

3:30
Morning Networking Refreshments
3:45

DATA PROTECTION & GDPR POST-IMPLEMENTATION?

Common Challenges to Implementing the GDPR, the First Data Breaches and How to Minimize the Risk of an Enforcement Action

Sandra Mori
Data Privacy Officer (DPO) Europe
The Coca-Cola Company (Italy)

Laura Liguori
Partner
Portolano Cavallo

Filiberto E. Brozzetti
Consigliere giuridico
Garante per la protezione dei dati personali

  • Where do you focus your GDPR compliance efforts post-implementation?
  • How the compliance department and the data privacy department work together to meet and maintain full compliance post GDPR
  • How to maintain compliance with GDPR when handling employees and third parties’ personal data during internal investigations
  • Measures to put in place to handle the data generated by companies’ whistleblowing systems and data collected in due diligence
  • How do you deal with a request for the right to be forgotten in relation to data?
  • Identifying what a data breach is, when it may occur and when it happened?
  • How to deal with data breach and build a continuous relationship with your local data privacy authority

4:30

PUBLIC PROCUREMENT WITHIN ANTI-CORRUPTION AND ANTI-MAFIA BOUNDARIES

How to Strengthen Tender Systems and Internal Processes to Control New and Evolving Corruption Risks

  • Recent developments in Italy’s bidding and public procurement regime
  • Anatomy of a public tender: identifying risks in open, semi-open, or by invitation bidding scenarios
  • Risk management in situations where applicability of bidding rules is unclear
  • How can you challenge bid results that you believe involve corruption?
  • Involvement of agents in public bidding, how to mitigate risks of corruption

5:30
Conference Ends & Closing Remarks

Workshop A | A Deep Dive into LD No. 231/2001, UKBA & US FCPA: A Practical Guide to Assessing Varying Compliance Risks and Embedding Essential Requirements and Expectations into Policies & Processes

Mar 12, 2019 9:00am - 12:30pm

€500

Speakers

Federico Busatta
Partner
Gianni, Origoni, Grippo, Cappelli & Partners

Robertson Park
Partner
Murphy & McGonigle

What is it about?

This hands-on working group will provide an overview of the costliest anticorruption settlements recently issued. Now that you are aware of the allegations and the factors that were taken into consideration to reach the resolutions, what could have been done differently? The working group will equip you with the crucial tools to proactively detect potential weaknesses to address them before any external party involvement.

  • The latest FCPA penalties involving bribes paid to government officials in exchange of government contracts and books and records violation
  • Major regulatory developments of the FCPA and their relevance to Italian companies
    • Yates Memo’s amendments with respect to civil investigations
  • Who is a “foreign official” under the FCPA, the UK Bribery Act and the LD 231 and how to deal with employees of state-owned enterprises
  • Key enforcement agencies in Italy, the UK and the USA, their roles, jurisdiction and how they cooperate
  • Offences companies can be held criminally liable for under L Decree 231/2001
  • Italy’s anti-corruption enforcement cases and their impact in the interpretation of the LD 231
  • Specific concerns regarding the interaction between anti-corruption enforcement and other areas of law, such as labour law and data protection
  • The arsenal of sanctions and penalties Italian prosecutors can use
  • Lessons learned from the UK DPAs under the UK Bribery Act
  • Enforcement and investigations on individuals across the three jurisdictions: how do they compare?
  • Books and records requirements: Maintaining records that “accurately and fairly” reflect transactions
  • Challenges in coordinating investigations in multiple jurisdictions; double jeopardy, privilege and privacy
  • Protecting privilege during investigations and reporting to the government; how realistic is it?
  • Compliance programme requirements and defence: key practical takeaways for compliance executives

WORKSHOP B | How Industry is Updating Third-Party Onboarding, Monitoring and Auditing in High Risk Markets: New, Special Considerations for Vendors and JV Partners

Mar 12, 2019 1:30pm - 5:00pm

€500

Speakers

Silvio Cavallo
General Counsel
Pillarstone Italy

What is it about?

This in-depth, smaller-group session offers a unique opportunity to benchmark your third-party risk management system with your peers. Experienced workshop leaders will discuss local as well as international regulators’ expectations for an effective third-party management strategy with an emphasis on where organisations are innovating and what are they doing differently. The workshop will include a series of interactive scenarios including a focus on third party due diligence, as well as compliance with GDPR. Topics covered include:

  • How to create a strategic plan for continuously monitoring an ongoing, existing relationship with third party business partners
  • When and how to monitor anti-corruption compliance on longstanding vs. new business partners
  • Determining whether you need any outside help for ongoing intermediary and partner due diligence
  • What to do with information uncovered during the continuous vetting process: How to identify and evaluate red flags
  • Addressing unique challenges associated with specific types of third parties faced by global businesses:
    • Distributors, vendors, lower tier suppliers
    • Customs brokers and agents
    • Local consultants and legal advisors, marketing intermediaries and introducers
    • Foreign currency converters, travel agents
    • Other local business partners
    • Joint ventures or affiliates
    • Government ownership
  • Examining commission payments and the performance of the service the third-party is engaged to do
  • When to consider terminating a third-party relationship over bribery suspicions: Anticorruption, contractual, and other key considerations
  • What to do when third parties are not cooperating, including challenges to accessing records, and gaining answers to questionnaires and follow-ups