Robust third-party due diligence (TPDD) is essential for an effective, solid and risk-based compliance programme. Understanding compliance concerns and risk appetite, defining third party scope, accurate screening, appropriate mitigation plans and continuous monitoring are fundamental steps of TPDD.
Ipragaz started to implement TPDD as part of its Ethics & Compliance programme several years ago. Two different teams were established. The first was a team of four members of staff at Ipragaz. Each team member specialises in and is responsible for one specific business activity (such as LPG, automotive fuel or bulk sales). The second team was made up of five members of staff at EVAS, where each team member specialises in one of the relevant geographical areas.
"We continuously improve our third-party due diligence process to make sure it both adequately helps to mitigate the potential risks and at the same time ensures smooth continuity of business operations"
Ceren Hacialioglu, Compliance Officer at Ipragaz, summarises the approach to TPDD: “We continuously improve our third-party due diligence process to make sure it both adequately helps to mitigate the potential risks and at the same time ensures smooth continuity of business operations.”
From one-size-fits-all to a tailored approach
As part of our continuous improvement process, we realised that our organisation needed to adopt a tailored approach. EVAS is exposed to a potentially high level of risk due to its LPG cylinders being exported to more than 70 countries. Initial pre-screening of the third party is performed during the proposal or negotiation process. However, the real engagement usually starts with the first shipment, invoice or payment. Therefore, the duration between the two phases may be long enough for a dramatic change in export control rules or trade sanctions, or even in the reputability of our business partners.
With this in mind, we introduced a second stage of screening. This is performed by the Finance Department before each invoicing and shipment. It enables us to catch any change in export rules or sanctions before each engagement with third parties and provides an opportunity for early determination of deviations.
Going forward, we will continue to adjust and improve our third-party due diligence approach to ensure it meets the necessary legal requirements, as well as our internal needs, supporting us to mitigate third-party risks in an effective manner.