Because of requirements of the Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act, when arranging a contract with an off-shore vendor, companies will conduct due diligence which may include asking the vendor to complete a questionnaire.  The answers may lead to an additional investigation to make sure that any 'red flags' that arise will not pose a risk to the company.

We need to decide how long to keep these questionnaires for vendors we contract with as well as for those we reject.  It seems that for audit purposes we need to keep them for the life of the contract, but how long after that? The standard 6 years? In most cases these may be electronic documents that are on a system disassociated from the contract itself.  What is the risk of destroying these too soon?

Has anyone had to deal with this issue and been provided guidance on a best practice?  All suggestions are welcomed.


Carolyn

Carolyn Mariani
Director, Records Management
Warner Music Group
75 Rockefeller Plaza
New York, NY 10019
[log in to unmask]<mailto:[log in to unmask]>
212-275-2410


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