The 55.4 percent that do have plans to improve their corruption programs are "in line with the government's expectations," says Bill Pollard, a partner in the FCPA consulting practice of Deloitte Financial Advisory Services LLP.
The number of companies making improvements, however, is steadily increasing, he adds, "because the government's vigilance in enforcing the FCPA is driving behavior." But the number is still not where it needs to be, given the fact that "almost half of the companies that were part of our survey were not planning, or didn't know if they were planning to make any changes," Pollard observes.
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Many Officials Don't Know if Their Companies Comply with Foreign Corrupt Practices Act
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