For many companies, the prospect of hiring a compliance monitor is one of the scariest elements of negotiating a settlement with U.S. anti-corruption enforcers. Avon Products Inc. (Avon) faced that fear when it entered into a settlement with both the DOJ
in late 2014, but through its significant remediation efforts was able to limit its monitorship to just 18 months, with an additional 18 months of self-reporting. Earlier this month, Avon was acquired by Natura & Co., the owner of The Body Shop and Aesop, creating the fourth largest pure-play beauty company in the world. The Anti-Corruption Report recently spoke with Richard Davies, Avon’s chief compliance officer, about navigating the monitoring, self-reporting and post-monitorship period. In the first part of this two-part series, Davies discusses the company’s remediation efforts, how it learned from its monitor and how the self-reporting period served as a useful transition between the pre- and post-monitorship periods. In the second part
, he discusses life after the monitoring period and the opportunity to innovate the program as part of Avon’s ‘Open Up’ turnaround strategy and move ahead after its acquisition. See “Adelle Elia of LBI Offers Insights on Working Effectively With a Monitor
” (Jul. 24, 2019).