China question: What is the best way to implement a compliance programme?

The international perspective

To establish an effective compliance programme, it is advisable to set up and maintain compliance and anti-corruption policies that are both legally compliant and commercially practical on both a global and a local-level. It is an especially daunting task when operating in a country like China, which is perceived to have higher compliance risks.

In the past, we have seen companies act from convenience and apply global policies directly to their Chinese subsidiaries by publishing those policies on the company's intranet. However, this approach does not ensure the policies are fully compliant with PRC law. In addition, the policies may not have taken into consideration industry practice and local business needs in China.