One key global compliance program is Avon's Anti-Corruption Program. In 2010, Avon launched its current Global Anti-Corruption Policy, which outlines Avon's commitment to comply with anti-corruption laws, both in the U.S. and abroad. The Policy focuses on compliance with the U.S. Foreign Corrupt Practices Act (the "FCPA"), as well as other anti-corruption laws, and provides Avon Associates with specific guidance on appropriate interactions with non-U.S. Government Officials.
A key component of this Policy is Avon's Third-Party Anti-Corruption Review Procedure, which evaluates anti-corruption risks associated with Avon's use and retention of certain third parties, and ensures Avon's continued compliance with the FCPA and other anti-corruption laws. This procedure requires certain third parties to undergo an extensive due diligence process with multiple levels of approval before the third party can be retained by Avon.
To drive Avon's commitment to its Anti-Corruption Program, many Associates worldwide have participated in mandatory, in-person training, focused on Avon's policies and procedures, and compliance with the FCPA and other anti-corruption laws. Depending on the Associates' job functions and responsibilities, this in-depth training took place over one or two days and provided the Associates with guidance regarding the law, its application to Avon and their specific job functions, and resources for additional information and further guidance. The training covered a cross-section of Avon policies, procedures, and internal controls designed to detect and prevent violations of the FCPA and other laws.
By the end of 2011, Avon will have conducted in-depth, in-person training sessions on the Anti-Corruption Program for select Associates in almost every direct market worldwide. In addition, more than 99 percent of Associates with Avon e-mail accounts have completed the company's tailored on-line anti-corruption e-training module. This module and other compliance e-training courses are now automated as part of Avon's on-boarding process for new Associates. Additional in-depth, in-person compliance training and e-training is planned for 2012.