Sam Eastwood

Monitorships

• World Bank-appointed monitor – Sam acted as Independent Compliance Monitor for Macmillan Publishers Limited (18 months), reporting to the World Bank and the Serious Fraud Office in connection with corruption issues which led to its debarment (2011-2013). At the of the monitorship period the company successfully applied for release from debarment.
• Sam has also had quasi-Monitor appointments for an Australian international engineering consultancy and an Azeri technology company which had also been debarred by the World Bank. The companies were both encouraged by the World Bank’s Integrity Compliance Officer to retain an independent adviser to help them review and reinforce their compliance programme so that they could apply for release from debarment at the earliest possible stage - which they both successfully did.

Investigations

• Carrying out internal investigations for a multinational mining equipment manufacturer, which resulted from a whistleblower report while a global compliance review was taking place. This involved extensive data review, forensic analysis and key personnel interviews as well as the management of remediation arising from the termination of third party engagements.
• Advising Telia Sonera, a Scandinavian multinational, in a substantial investigation and review of its Eurasian acquisitions (Azerbaijan, Kazakhstan,Tajikistan, Nepal, Georgia) reporting to the Chairman of the Board who set out our findings at Telia Sonera’s Annual General Meeting.
• Investigation into alleged corrupt dealings with Chinese state-owned entities by US and European entities of a multinational corporate. Reporting to the board of directors and design of remediation programme and compliance improvements.
• Representing Tullow plc in relation to its joint venture operations in Ghana (with Kosmos and Anadarko) and a World Bank investigation into the activities of their joint venture’s FPSO operator.
• Investigation into two Chinese Distributors of a multinational manufacturing company in response to a whistleblower report.
• Advising a large management consultancy practice on its response to allegations relating to its involvement with Gupta associated entities in South Africa and conducting an investigation into its activities in that jurisdiction for two State owned entities.
• Investigation in Kazakhstan for a global logistics company relating to its customs activities following press reports in the Wall Street Journal.
• Investigation in Turkey for a technology company in response to a whistleblower allegation relation to the procurement of an important licence in that jurisdiction.
• Investigation into the Indian operations of a FTSE 100 manufacturing company and advising them on the appropriate compliance steps to respond to weaknesses identified in their compliance program.
• Investigation into the activities of a former African country manager of an oil and gas multinational and related compliance programme review.
• Numerous other internal investigations for a range of industries (financial institutions, engineering, technology, oil and gas, etc).

Compliance

• Designing and implementing a global compliance programme for a large multinational company, which involved a secondee working in the in-house legal team, fieldwork in Brazil, China, India, Kazakhstan, Russia, Ukraine, the United States and Finland, numerous investigations and managing potential criminal exposure in Austria, Poland and other jurisdictions.
• Audit and testing of a global manufacturer's compliance programme, including transaction review and interviews in China, Singapore, Dubai, Europe and the United States. Reporting data-driven results and recommendations to the board of directors. Developing and executing remediation plans relating to financial control and compliance process improvements, training and employee discipline.
• Assisting a leading aerospace and defence company to establish a consistent methodology to assess the remuneration paid to third parties that meets the required standards of international anti-bribery legislation.
• Assisting an oil and gas multinational with the management of its high risk third party program mandated by the US Authorities.
• Reviewing the compliance programme of a multinational construction company and delivering to the Board recommendations for its development.
• 15 month review of financial institution’s third party management programme which included secondments of associates to facilitate the management of the project.
• Designing and delivering anti-corruption programs or elements of programs (training, risk assessments, third party programs, investigation and internal audit functions) for a range of corporates across numerous sectors.
• Advising a Big 4 Audit practice on its response to indications of impropriety relating to the activities of one of its audit clients African subsidiaries.
• Advising multinational companies on the development of human rights related policies and procedures, responses to the demands of institutional investors regarding their human rights and labour welfare policies and procedures and responses to human rights related legislation including the Modern Slavery Act.
• Advising financial institutions on their response to the Criminal Finances Act (failure to prevent tax evasion) and helping them to work up a risk assessment and suitable policies and procedures to address the identified risk.

Transaction support

• Conducting mergers and acquisitions integrity due diligence for various international companies, as well as developing post-acquisition compliance integration plans.

• England und Wales
• Solicitor Advocate and Accredited Mediator

• Sits on the board of Transparency International UK
• Sits on the board of the Management Committee of University College London’s Centre for Ethics and Law
• Member the City of London White Collar Crime Committee
• Co-chair of the Professional Against Corruption Group which he helped to set up at the time of the UK anti-corruption summit in 2016
• Founding member of the International Association for Independent Corporate Monitors