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Resource alert: UH database facilitates FCPA compliance benchmarking

Last week, the University of Houston Law Center released the most comprehensive free dataset for compliance benchmarking available. The Fortune 500 Code of Conduct dataset allows anyone to access the University’s website (without the worry of future spam emails that come with a “free” registration) and search through three years of data the Law Center has put together covering over forty different compliance areas including the Foreign Corrupt Practices Act. 

The database can be accessed here.

While most companies with FCPA risk typically have some sort of internal policies and procedures governing their FCPA compliance program, this dataset allows companies to see, for instance, data as high level as how many companies have FCPA policy language in their codes and what the language looks like to specific data points, such as how many of companies have included facilitation payments in their codes of conduct and which companies prohibit such payments.

The dataset took over 2,000 hours to put together and began as a business development project in 2010.  It allows companies to spot trends (are facilitation payment prohibitions increasing?) and identify general policy language for benchmarking purposes.

We’ve put together some detailed statistics below:

Number of companies addressing the FCPA:

2011: 260
2012: 268
2013: 290

Number of companies addressing facilitation payments:

2011: 117
2012: 136
2013: 150

Number of companies prohibiting facilitation payments:

2011: 19
2012: 39
2013: 47

Number of companies defining foreign official:

2011: 98
2012: 116
2013: 116

And these statistics only scratch the surface of how compliance professionals can use this free dataset. 


Ryan McConnell and Michelle Jee are lawyers at McConnell Sovany — a boutique law firm in Houston that focuses on corporate compliance consulting, criminal defense, and plaintiffs’ litigation. McConnell is a former federal prosecutor who teaches criminal procedure and corporate compliance at the University of Houston Law Center. He originally conceived of and developed the codes of conduct dataset in 2010 and turned over its management to UHLC last year. Jee is a UHLC graduate whose practice focuses on the design and implementation of global compliance programs. Please send comments about the database or issues with searches to [email protected].

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