Page 195 - Bundle for MF Final

Bates no 194

ANTI-CORRUPTION TRACK RECORD
Comer has been at the front line in preventing. detecting and
investigating corruption for the past 40 years :
• Internal disciplinary cases In HM Customs and Excise involving
skulduggery by inspection staff;
• Advising and investigating the anti-fraud and corruption work of the
Esso-Shell-BP joint investments in the North Sea: making multi-million
pound recoveries from overcharging by supposedly reputable
contractors;
• Supporting all of Esso's construction and logistics investments
throughout Europe;
• For nine years advising the Jamaican government, working inside and
reforming its Revenue Protection Division. In this role he observed first
hand how and why agencies become systemically corrupt and how
they can be changed for the better;
• Advising and working inside revenue departments in four ASEAN
countries and supporting SGS on its Customs and inspection services in
Indonesia, Philippines. Malaysia, Taiwan and Hong Kong.
• Advising Anti-Corruption Units in Indonesia. Brunei and Malaysia

• Directing scores of corruption investigations in the construction,
banking. entertainment and pharmaceuticals sectors throughout the
world. Serving as lead Investigator for Citibank, Barclays Bank and ABM
Amro in a $2 billion corruption case in the UAE
• For 5 years managing the integrity hot line ("whistle blower") for a
leading Gulf Oil company, filtering and assessing reports and specifying
investigations plans
• Advising three leading companies in the oil and gas, extractive and
financial services sectors on controls, audit and continuous monitoring
programmes that surpass the requirements of the Bribery Act and FCPA
• For 18 months served as a Monitor and expert witness-under the
direction of Peter Taylor QC-for two public companies and casino
operators which were subject to regulatory action
• Developed an automated program-consisting of 1,000 specific and
validated tests-to detect and continuously monitor potential symptoms
of corruption and related frauds

He has also been responsible for marketing his companies' services world­
wide. often in countries perceived to be corrupt. He has succeeded without
ever paying or receiving a bribe. by being able to recognise vulnerable
contexts and using "verbal judo" techniques which he now teaches to in
company teams.
Between 2016 and 2018 he advised the Govement of Mauritius on an
integrity programme that resulted in a change to the Country's
Constitution. triggered the Good Governance and Integrity Reporting Act
and created the Integrity Reporting Board headed by Baron Phillips. KC.PG.
the inaugural President of the Supreme Court of the United Kingdom.

CO BASCO