Coloplast Distributor Due Diligence Process · 2020-05-23 · Steps in implementing Coloplast’sdue diligence process Page 6 29 september 2016 1. Decision on approach 2. Decision

Coloplast Distributor Due Diligence ProcessConsiderations in implementation29 september 2016

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What will we cover in this session?

29 september 2016 Coloplast Distributor Due Diligence ProcessPage 2

1. Implementing Coloplast’s Distributor Due Diligence Programme

2. Supporting tools/systems

3. Prerequisites for success

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Coloplast Annual Report 2014/15

We’re a global company

10,000employees

13.9 BNDKK revenue

Representedin 42 countries

Products soldin 136 countries


Who are our typical consumers, and how do wehelp them?

People with difficult-to-healwounds

We help withWound & Skin Care

People suffering from urological and pelvic healthdisorders

We help withUrology Care

People in need of bladderor bowel management

We help withContinence Care

People who have had their intestines redirectedto an opening through the abdominal wall

We help withOstomy Care

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Implementing distributor due diligence

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Steps in implementing Coloplast’s due diligence process

29 september 2016Page 6

1. Decision on approach

2. Decision on scope

3. Decision on supporting tools/systems

6.

5. Design of process/workflows

4. Design of questionnaires and risk rating model

Coloplast Distributor Due Diligence Process

Internal and external communication

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Step 1 - Approach

A

Approach?

1

Only new or also current distributors?

B

Transparent with distributor involvement – vs. closed internal process?

Global process or for selected countries only?

C

Coloplast’s choices

Approach

An open approachactively involvingthe distributors Both new

and existing distributors

All geographies

Supported by systems and

processes

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Coloplast’s choice

• Transparency – enables cooperation with distributor on mitigating findings, if any

• Involvement of distributors - Questionnaires/information

• Strong audit trail - All information/documentation kept in one place

• Ongoing continuous monitoring- Tool can support with monitoring

Benefits

• Interference with business•Requesting customers/distributors to complete questionnaire• Involving business in process – keeping it a priority

• Implementation also for current distributors (even distributors with a long working relationship with Coloplast)– not always understood or well received

Challenges

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Step 2 - Scope

?

Scope?

2

Solution – making Coloplast’s distributor definition in collaboration with business

!

Challenge – no uniform terminology on “distributor” across business units at Coloplast

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A few remarks on scope and definition

The final scope/definition will differ by company and industry – what are the risks involved in your particular company and industry?


Bidding on tenders for

you?

Joint marketing

efforts?

Interaction with

government officials on

your behalf?

Other?

Even with the definition, the precise scope was discussed in detail withthe people responsible for the distributors in each country/business unit

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Step 3 - Decision on tools/systems (I)

A

Tools and system needs

3

Tool to handle questionnaires –automated process

Screening tool a.o.including business information on ultimate ownership, adverse media, pep and sanctions lists – initial risk rating

Investigation reports

Repository –track record/documentation

EDCB

Monitoring

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Step 3 - Decision on tools/systems (II)


Require-ments

IT security (system security,

disaster recovery, etc.)

Data privacy (meeting data

privacy requirements)

One stop shop (to the extent

possible)

Choice of vendor

Involving internal

procurement and IT

specialists

Asking other companies

for references

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Step 4 - Questionnaires and risk model

?

Question-nairesand risk model

4

Automated risk rating in both tools•Based on specific industry risks and company risk appetite•Decides further process for distributor due diligence

!

One or more questionnaires?•Internal/external•Variations by country/region?

Risk

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Step 5 - Process design

A

Process design

5

Roles and responsibility•Business involved in more steps of process•Administrative roles in Shared Business Centre (Poland)

B

Work flow•Challenge – Coloplast’sorganisation varies by region – system workflows to reflect this •People change at both ends – workflows must change accordingly

What triggers external investigation?

C

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Our internal process/ workflow:

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Our process seen from the distributor’s side


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Step 6 - Communication

Communication

6

• Internal pre-launch communication• Internal launch communication • External communication• Reporting

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Internal communication (I)


• Roles and responsibility in each region/country/business unit

• Discussion with distributor responsible for each business unit to ensure scope is met according to definition (physical meetings/skype meetings)

• Discussion of translation needs• Process materials• Introduction to system

Internal pre-launch communication

• Introduction ppt• Back ground information• Step-by-step guides

Internal launch communication

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Internal Communication (II)


• All materials are available on Coloplast’s intranet:

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• Reporting to business• Reporting to CEO• Reporting to Audit Committee

• Face to face communication in business meetings

• Various information materials on website• Focus on the upsides and the business

partnering

External communication and internal reporting


External communication Reporting

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External Communication

• Materials on website:


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Supporting tools and systems

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Tool for database search – Bureau van Dijk (BvD) Compliance Catalyst• When the distributor has completed the questionnaire, Corporate Compliance conducts a database search

in BvD and upload the report into Compliance Desktop (see next slide)

• What do we get from BvD?

• BvD offers comprehensive corporate information including ultimate ownership (Orbis report)

• Compliance Catalyst combines data from Orbis with:

• PEPs* and sanctions lists data

• Adverse media from WorldCompliance

• Ongoing monitoring and audit trail

• Risk rating based on Coloplast risk profile

*Politically Exposed Persons


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Example of BvD Database search


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Tool for other parts of the process – Compliance Desktop and external due diligence reports (conducted by RFG)

• Red Flag Group (RFG) uses all information provided in questionnaires and BvD reports, and conducts on-the-ground investigation – final report is uploaded into the system


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What are the prerequisites?

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Steps in implementing Coloplast’s due diligence process

29 september 2016Page 28

1. Mandate from top management – the company must be ready to walk the talk• What do you do, if a distributor presents a high risk?• What if they do not want to participate in the process?

2. Clear scope/definition

3. Clear roles and responsibilities with business

5.Time – implementation will most likely take up more time and resources than you expected both with regard to systems and with regard to processes

4.Good systems and reports will definitely help – have you made your business case and got the budget?

Coloplast Distributor Due Diligence Process

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Documents

Coloplast Distributor Due Diligence Process · 2020-05-23 · Steps in implementing Coloplast’sdue diligence process Page 6 29 september 2016 1. Decision on approach 2. Decision