What We Do

• ESG Program Development and Integration
  
• Compliance Risk, ESG and Program Assessments (including related pre-acquisition diligence)
• Developing, Improving and/or Integrating Compliance Programs
  
• Address Compliance and ESG for Investments, Start-ups and Capital Expansion (private or public)  
• Compliance Issue Response (including Investigations, Settlements, Expert Testimony, Asset Recovery and Remediation)

ESG Program Development and Integration

GCMR Team members are at the forefront of the global efforts around ESG reporting and compliance.  GCMR is taking a holistic and measured approach in helping organizations determine the best way to address their particular ESG needs.  This includes helping to analyze current ESG areas important for the organization, and importantly, help the organization be prepared to address other areas of ESG that the company may decide to address in the future.     

GCMR Team members will help you:  

• Know the details of current or to be implemented ESG related laws, standards or requirements and assist with developing well organized and easy to understand recommendations to effectively address ESG issues.
• Understand the elements and metrics used by the different ESG rating organizations and keep you updated on the recent efforts to harmonize those for both local and global tracking purposes.
• In a comprehensive and objective manner, evaluate the current and potential ESG reporting elements for your company considering possible impacts, both positive and negative, to the company.
• Develop internal, cross functional processes and guidelines to organize and track ESG related information for immediate or possible future reporting.  GCMR understands that ESG is multi-functional and disciplinary and therefore works to facilitate a cooperative internal team approach to the tracking and organizing of data.    

Legal/Compliance Risk, ESG and Program Assessments

GCMR Team Members have particular expertise in conducting detailed legal risk, process risk and compliance program assessments as well as working with Clients to better understand how ESG may relate to and impact their business.   

The assessments can be done globally for the whole organization or for a particular line of business, a region or a country.  The assessments can address new risks or issues that may arise due to new or newly identified internal or external circumstances. 

GCMR will always ensure that the right individuals with the right knowledge will be involved in any assessment.  GCMR also understands the sensitivity of such assessments and works with the company in determining the scope of work and structure of reports. 

GCMR will:
 [Legal/Compliance Risks, ESG]

• Following careful scoping of the project and development of agreed upon work plans, conduct a comprehensive legal risk assessment relating to areas such as anti-corruption, trade controls, anti-trust, data privacy and others including logistics and customs requirements.
• Always tailor the risk assessment to the company, taking into account the business, markets and geographies, and where helpful, align the work plans and reports to any existing enterprise risk management (ERM) process.
  
• Ensure that the risk assessment includes an analysis of current compliance/mitigating efforts as well as recent or expected significant business events such as mergers and acquisitions.
• Working closely with internal subject matter experts (including ESG related teams in place), assist the company in assessing its current ESG efforts/program to help determine effectiveness, accuracy of data and/or possible process improvement opportunities.  Integrating ESG into the overall risk profile of the organization is important.

[Compliance Programs] 

• Assess the corporate compliance program and any specific regional or country implementations under applicable country or international standards (such as U.S. FCPA, UK Bribery Act, ISO 37001, etc.) as determined by the company, with input from GCMR .
• Assess other company compliance related processes such as export controls, sanctions, international and domestic transportation of goods, anti-trust, data privacy, supply chain integrity, child labor, and conflict minerals.
• Provide objective and where applicable, attorney client privileged feedback. If requested as part of the agreed upon project scope, provide recommendations to address possible gaps or continuous improvement opportunities.
  

Developing, Improving or Integrating Compliance Programs

GCMR Team members have extensive experience in successfully designing, implementing, monitoring and improving comprehensive corporate compliance programs. GCMR understands that compliance programs need to be risk based and designed to be highly effective within the organization, globally.  GCMR also understands that the type of resources allocated to an effective compliance program should in part be based on the size and complexity of the organization.  

GCMR can help you:

• Understand and assess the regulatory requirements and related compliance program recommendations with a focus on how those may relate to or impact your business.
• Develop specific proposals and high quality work product for enhancing your current compliance program or implementing a new compliance program. This type of assistance is valuable for new entities, small to mid-size companies that are considering what is important for their organization and any company that is looking to make its compliance program more effective and efficient. 
• Evaluating and addressing compliance program risks and opportunities associated with mergers and acquisitions or other business changes such as new markets or establishing operations in a new country.  
• Objectively analyze and determine how the numerous technology offerings relating to compliance programs could impact your global compliance efforts, risks and resource commitments, both positively and negatively.

Address Compliance and ESG for Investments, Start-ups, and Capital Expansion (public or private)

GCMR Team Members have significant experience working with or addressing issues for a wide range of investment firms, financial institutions, development banks and start-ups.  GCMR understands from the investment and financing side, as well as from a company perspective, the important Compliance and ESG issues that should be addressed.  GCMR always addresses such issues with a risk-based approach understanding the resources and time available for diligence can be limited.   

GCMR is available to also:

• Work closely with investment firms and private family offices on target and acquisition diligence and portfolio company compliance, risk and ESG management.   
• Advise privately held entities on compliance, risk, governance and ESG matters required in advance of IPO/SPAC transactions as well as during and following such transactions.
• Handle sensitive, complex and strategically critical corporate crisis’, turnarounds and restructuring situations involving complex compliance issues, risks, governance and related ESG challenges.   
• Bring competitively advanced technological, as well as sustainable and profitable solutions to such challenges. 

Compliance Issue Response (including Investigations, Settlements, Expert Testimony, Asset Recovery and Remediation)

GCMR Team Members have significant and unique experience in managing a wide variety of compliance issues that companies may have to address as part of their ongoing business operations.  From leading smaller investigations, to managing all compliance obligations relating to multi-billion dollar government settlements, GCMR has the legal and forensic accounting expertise to assist your company to properly address compliance issues with a focus on the “right response”; not doing more or less than is justified based on the circumstances and the actual risks.  In addition, Team Members have expertise in formal Asset Recovery efforts and have been involved in providing expert testimony for compliance and accounting related matters.  

GCMR can assist you by:

• Conducting independent investigations of sensitive issues including those relating to anti-corruption, anti-trust, trade controls, human resources and other regulatory related issues. All investigations will be conducted following an agreed upon investigation plan consistent with recommendations by any applicable government regulator.  In addition, the reviews will typically include a root-cause analysis and will be managed using project management tools to promote effective communication, meeting of agreed upon timelines, other KPIs and proper data management.
• Providing legal and practical input as a company is addressing possible settlement discussions with regulatory agencies. This input will be based on years of “real life” experiences (internal and external) and will always include a focus on the likely impact of such settlements on the business at both a corporate and local level.
• Assisting in managing the compliance obligations associated with government settlement agreements such as Deferred Prosecution Agreements, Plea Agreements, Consent Decrees, Sanction Agreements, Negotiated Resolution Agreements, and others. Any ongoing interactions with regulators and other third parties involved must be carefully and properly managed.  In addition, a thorough, easy to understand and monitor internal compliance process must be developed and implemented.