29! ! GSK IN CHINA A New Dawn in the Fight Against International Corruption Thomas Fox AUTHOR Thomas Fox is the Principle of Advanced Compliance Solutions and practices anti- bribery/anti-corruption compliance in Houston, Texas. He is the author of several books dealing with anti-bribery and anti-corruption, including most recently Doing Compli- ance: Design, Create, and Implement an Effective Anti-Corruption Compliance Pro- gram. He is the Founder and Editor of the FCPA Compliance and Ethics Blog, is a Con- tributing Editor to the FCPA Blog, a Contributing Writer to Compliance Week, is a featured contributor to Corporate Compliance Insights (CCI) and is a Columnist for the Society of Corporate Compliance and Ethics (SCCE) magazine. He is the author of nu- merous articles on the FCPA, UK Bribery Act and compliance and ethics. He is also an internationally recognized speaker in the field of anti-bribery and ant-corruption compli- ance. He can be reached at
[email protected]. PAGE 29 COMPLIANCE ELLIANCE JOURNAL | VOLUME 1 NUMBER 1 2015 ! ! THOMAS FOX | GSK IN CHINA PAGE 30 TABLE OF CONTENTS I. BACKGROUND 31 II. GSK FACES A BAD DAY AT BLACK ROCK 33 III. THE SEX TAPE 35 IV. INTERNATIONAL RIPPLES FROM CHINESE CORRUPTION INVESTIGATIONS 37 V. HUMPHREY AND WIFE CONVICTED 39 VI. GSK CONVICTED 41 VII. THE VERDICT 43 VIII. WHAT CAN YOU DO WHEN RISKS CHANGE IN A THIRD PARTY RELATIONSHIP 46 IX. COMPLIANCE LESSONS LEARNED FROM GSK IN CHINA 48 A. Integrating Your Risk Assessment 48 B. Board Oversight and Tone in the Middle 49 C.