b'Compliance Matters Compliance MattersPublicly-Traded Global Energy Company Publicly-traded Infrastructure Company, Latin AmericaProactive Compliance Review, Program Implementation and InterimProactive Compliance Review, Forensic Technology and eDiscoveryCompliance Officer Assistance Due DiligenceStoneTurn professionals were retained to perform a preliminary analysis of a publicly-traded globalStoneTurn was engaged by external counsel to assist one of the largest infrastructure concession energy companys ethics and compliance program. In response to the teams recommendations,companiesinLatinAmericawithaholisticassessmentofitscomplianceprogramandanti-the scope of our efforts was expanded and StoneTurn professionals served on-site as an interimcorruption controls. The StoneTurn team utilized forensic technology, eDiscovery, data analytics Compliance Officer, concurrently responsible for the day-to-day operation and the design andand on-site interviews of key personnel in Portuguese,as part of its due diligence around contract implementation of enhancements to the organizations global ethics and compliance program.and bidding protocols. In addition, StoneTurn professionals assessed available data in order to Thisworkspannedcriticalprogramelementssuchasthird-partyduediligence,investigationflag any potential areas of concern for counsel and the Audit Committee, and recommended protocols, anti-bribery and anti-corruption control improvements (including assistance with on- enhancements to policies and controls designed to prevent misconduct.siteinternalaudits),CodeofConductbenchmarking,employeecommunicationsandtraining (including a Speak-Up Culture awareness campaign), and legal and compliance governance. Our multi-disciplinary team of former in-house counsel, compliance officers, prosecutors and auditorsU.S. Technology and Multimedia Companyaided in designing and implementing a holistic ethics and compliance program for the client.Compliance Adviser; Internal InvestigationsStoneTurn was retained by an American technology and multimedia company to serve as an Private Equity Firm external compliance adviser with responsibility for internal investigations, as well as overseeing Committee on Foreign Investment in the U.S. (CFIUS) Review complianceprojects.Inthisrole,StoneTurnprofessionalsinvestigatedmattersrangingfrom conflicts of interests to potential insider trading and drew upon our extended teams data analytics A StoneTurn expert was retained to develop a strategy and plan to address CFIUS concerns atand forensic accounting expertise to collect, review and analyze relevant source documents. In one of the portfolio companies of a private equity firm. The concerns largely centered aroundaddition, our experts provided the company with ongoing compliance support, including offering perceived supply chain weaknesses and business relationships with highly scrutinized countries.recommendations for compliance program enhancements based on investigation findings.These issues were preventing the merger of multiple portfolio companies and placed the entire deal plan and multi-billion-dollar investment at risk. StoneTurn helped to develop a strategy to eliminate CFIUS concerns and allow the planned consolidation to move forward. Pharmaceutical Education and Disposal CompanyProactive Risk Assessment and Compliance Program DesignStoneTurnwasengagedbycounseltoassistitsnot-for-profit,pharmaceuticalindustryclient with a comprehensive risk assessment, as well as a roadmap for a robust, risk-based compliance program. Our compliance experts conducted internal interviews, reviewed business documents and information regarding local and state ordinances in order to identify the organizations top risks, along with a prioritized compliance plan. The team identified enhancements to the organizations governance and structure; policies, procedures, and controls; training and education; and oversight and reporting to help better mitigate business risk. The findings were presented by the client to its Board and used to help justify additional compliance program funding and hiring.16 At Every Turn 2020 At Every Turn 2020 17'