STEP #
ACTION TO BE TAKEN
RESPONSIBLE PARTY
STEP #1:
Caterpillar business personnel identifies prospective or existing Third Party Intermediary and provides contact information (name of contact, name of legal entity to be engaged or involved and e-mail address) of that Third Party Intermediary to the Legal Services Division attorney supporting their business transaction. In the event that the Caterpillar business person does not have a Legal Services Division attorney supporting their business transaction then the information should be provided to William Hauptman in Legal Services Division – Peoria. Submitting this information will start the due diligence process.
Caterpillar business personnel
STEP #2:
Caterpillar attorney initiates due diligence process by importing Third Party Intermediary contact information into the due diligence system and an e-mail will be generated and sent to the prospective Third Party Intermediary containing a link to a secure web-site where the prospective Third Party Intermediary can complete the due diligence questionnaire.
Legal Services Division
STEP #3:
The prospective Third Party Intermediary must complete Caterpillar’s electronic due diligence questionnaire. Any failure to complete the questionnaire will result in an automatic rejection of the application to do business with Caterpillar.
Caterpillar’s due diligence system (i) is available in 18 languages, (ii) provides the ability for the Third Party Intermediary to easily upload the relevant information, (iii) allows for the tracking of the Third Party Intermediaries progress toward completion of the questionnaire, and (iv) notifies relevant Caterpillar parties when the questionnaire has been completed.
Prospective Third Party Intermediary
STEP #4:
After completing the questionnaire, the Third Party Intermediary must electronically certify that (i) it has read and understands Caterpillar’s Worldwide Code of Conduct and all applicable laws; and (ii) it is presently in compliance with, and, on an annual basis, it will re-certify that it remains in compliance with, all applicable U.S. and foreign laws and regulations.
Caterpillar’s due diligence system will automatically re-send electronic certifications to each Third Party Intermediary annually on January 1st of each year. Third Party Intermediaries have until February 1st of each year to re-certify. A Third Party Intermediary who fails to re-certify on an annual basis will be deemed to no longer be in compliance and is at risk of termination of its relationship with Caterpillar.
Prospective Third Party Intermediary