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Establishing system of internal control for a representative office of a foreign company

Saturday, 11 May 2019

Kosta Legal has advised a representative office of European pharmaceutical and cosmetics producer on establishing a viable internal control system that would ensure compliance with the Uzbek anticorruption laws and sector specific legislation.

A number of detailed policy documents have been elaborated prescribing rules for contacting state officials, holding public events, sending gifts, registering products with state agencies, organising training for raising the awareness about anti-bribery rules among employees and the main regulatory prohibitions affecting the industry. Some guidelines have been drafted based on the existing standard form documents provided by the European company, whereas others have been prepared from scratch to specifically address the Uzbek legal environment.

Much work was done to give these documents necessary binding force. We had to strictly comply with procedural rules set out by Uzbek law and intra-corporate regulations of our client.

Our client was a European pharmaceutical company, being amongst the world’s ten largest in terms of turnover and having representative offices in more than 70 countries.