Transparent Agents and Contracting Entities
TRACE, Inc. - Raising Standards Against Corruption
TRACE (Transparent Agents and Contracting Entities) is an international non-profit membership association working to reduce corruption in transactions in involving business intermediaries, including sales agents, representatives, consultants, distributors, joint venture partners and subcontractors. Companies looking for innovative ways to research "best practices", protect their reputation, promote transparency and business ethics, and meet anti-corruption compliance obligations and intermediaries seeking to commit voluntarily, publicly and decisively to greater transparency and ethical business practices can become TRACE members.
Due Diligence
Addressing Bribery, Kick-backs, Nepotism and Extortion
A TRACE due diligence background report meets the highest international standards for due diligence and helps intermediaries to adopt a written code of conduct addressing bribery, kick-backs, nepotism and extortion. A review of the company includes corporate structure, contact information, beneficial ownership, employees and third parties, local law, references, financial statement, disclosures, compensation, and media search. A number of “red flags” may require additional investigation.
Alexandra Wrage
Alexandra Wrage, an international regulatory lawyer, is the President of Transparent Agents and Contracting Entities. Ms. Wrage has written articles and guidebooks on compliance with the Foreign Corrupt Practices Act (FCPA) and the anti-corruption convention promulgated by the Organisation for Economic Co-operation and Development (OECD), and on anti-bribery due diligence, facilitating payments, gifts and hospitality to government officials and whistleblower programs. Ms. Wrage serves on the Steering Committee for Transparency International's Business Principles for Combating Corruption and supports the United Nations Global Compact.
Compliance Program
Shielding Companies from Liability
It is a criminal offense for corporations to make inappropriate payments (bribes) to foreign government officials directly or through a third party. Although no compliance program can prevent all inappropriate payments, a robust program squarely within international best practices can help to shield companies from liability if it can be shown that reasonable and prudent steps were taken to avoid - or identify and remedy - the situation. TRACE helps companies develop these programs quickly and cost-effectively.