STEP #5:
After receiving the questionnaire and certification, Caterpillar will conduct the appropriate level of due diligence as determined by the risk-based process noted above to attempt to identify any Red Flags. Generally, this process will include the procurement of a background due diligence review of the Third Party Intermediary by Caterpillar’s outside investigative services provider. The level of investigation will depend on the real or perceived risk(s) associated with the Third Party Intermediary in question.
Legal Services Division
STEP #6:
Attorney(s) in Legal Services Division review results of due diligence with business personnel to analyze potential risk and determine whether (i) the engagement or transaction may proceed; (ii) additional due diligence is required; or (iii) the engagement or transaction is not appropriate.
Legal Services Division and Caterpillar business personnel
STEP #7:
In the event is it determined that the engagement of or transaction involving the Third Party Intermediary may proceed, the contract with the Third Party Intermediary must contain (i) a specific description of the services the Third Party Intermediary will provide and (ii) the Caterpillar standard anti-corruption contractual provisions and certification requirements. These are available in the Anti-corruption Toolkit located at http://codeofconduct.cat.com/anticorruption.
Legal Services Division and Caterpillar business personnel
B.
Existing Third Party Intermediaries Who Have Previously Completed