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I have not put anything in a TPRM regarding insider relationships, this has always gone in the Employee Handbook. The wording varies but the gist of it is that an employee, contractor, etc. (insider) must disclose relationships with third parties. Depending on your location there may be legislation or regulation requiring the third-party and/or insider to disclose a relationship, e.g., anti-bribery.
Original Message:
Sent: 11-24-2023 04:01 PM
From: Anonymous Member
Subject: Third Party relationship with an insider
This message was posted by a user wishing to remain anonymous
Should we include a note in our TPRM policy in regard to third party relationship with an insider?
How do the rest deal with insider vendors?
Do you take any additional steps in your due diligence?
Thanks