It is much of the unlawful conduct outlined in the statement of facts agreed by the

parties to the DPA involved the inappropriate use of third-party intermediaries (TPIs).
TPIs include a variety of sales and marketing agents, consultants, brokers, lobbyists,
distributors, resellers, government intermediaries, joint venture partners and logistic
service providers, such as freight forwarders, customs agents or other travel or
transportation agents. The risks in using these TPIs can arise from their close
association with governmental officials, private customers or suppliers and the use by
them of improper offers or payments to obtain business or favourable governmental
treatment. However, the company must assign the roles and responsibilities regarding a
TPI to particular individuals. Thus, one individual should be appointed to propose and
manage the relationship with the TPI and others should have oversight and monitor the
relationship between the business contact and the TPI. Escalation procedures should
be put in place to refer matters to senior management, legal and/or compliance teams.