Covington & Burling LLP operates as a limited liability partnership worldwide, with the practice in England and Wales conducted by an affiliated
limited liability multinational partnership, Covington & Burling LLP, which is formed under the laws of the State of Delaware in the United States
and authorized and regulated by the Solicitors Regulation Authority with registration number 77071..
Sarah Bishop is a U.S. and UK-qualified lawyer who advises companies on ethics and compliance programs, compliance with anti-corruption and anti-money laundering laws, business and human rights (BHR) and environmental, social, and governance (ESG) matters, white collar investigations, and suspension and debarment.
Sarah’s compliance advisory practice includes helping multinational corporations develop and test the robustness of ethics and compliance programs, conducting risk assessments, conducting transactional and third party due diligence, supporting post-acquisition compliance integration projects, and delivering compliance training. She has particular expertise advising on the U.S. Foreign Corrupt Practices Act (FCPA) and UK Bribery Act and has advised companies in the energy, mining, pharmaceutical, healthcare, technology, and consumer goods sectors, among others, on anti-corruption compliance risks and program development.
As a member of Covington’s Business and Human Rights practice group, Sarah advises companies on the developing legal and enforcement landscape related to the corporate responsibility to respect human rights. She advises on enforcement risks under Withhold Release Orders (WROs), the Uyghur Forced Labor Prevention Act (UFLPA), and the Trafficking Victims Protection Reauthorization Act (TVPRA) in the United States, as well as developing ESG due diligence and reporting requirements in Europe. Sarah has helped multinational corporations in the healthcare, technology, automotive, energy, mining, and consumer goods sectors develop human rights due diligence programs, navigate human rights-related enforcement matters, and report on human rights due diligence efforts.
Sarah has extensive experience conducting internal and government-facing white collar investigations. Sarah has conducted investigations involving allegations of bribery, money laundering, export control and sanctions violations, fraud, human rights violations, and other forms of misconduct. She has handled matters before major international enforcement authorities and has been recognized in the Global Investigations Review Women in Investigations survey.
Sarah also assists clients in suspension and debarment matters before the World Bank and other international financial institutions.
Conducted an internal investigation into corruption allegations at the Indian subsidiary of a U.S.-headquartered company.
Led an investigation into whistleblower allegations of improper practices for a multinational pharmaceutical company under investigation by the U.S. DOJ and SEC.
Advised a multinational pharmaceutical company on interactions with the UK SFO relating to whistleblower allegations of bribery.
Supported an internal investigation into a large-scale employee fraud for a European-headquartered consumer goods company.
Conducted an internal investigation into a whistleblower’s allegations of bribery in a Middle Eastern subsidiary of a multinational technology company.
Conducted an internal investigation into potential sanctions violations by a European affiliate of a multinational pharmaceutical company.
Anti-Corruption Compliance
Provided regular anti-corruption compliance advice to a multinational energy company, including conducting a global anti-corruption compliance program review and advising on country entry risk assessments and M&A transactions.
Led a year-long anti-corruption risk assessment of a healthcare business acquired by a Fortune 50 company, including in-depth reviews and site visits in key markets in the Middle East, India, and Latin America.
Advised major Indian companies on U.S. and UK anti-corruption compliance standards in connection with investment transactions, including: a sell-side compliance due diligence review for an Indian company in connection with the sale of its healthcare business; advice on compliance program enhancements for an Indian company seeking to meet a U.S. investor’s compliance requirements; and advice to an Indian company responding to investor queries on a whistleblower investigation.
Supported a post-acquisition compliance integration project in countries across Africa for a multinational consumer goods company.
Provided regular anti-corruption compliance advice to a mining company operating in West Africa.
Collaborated with French counsel and accounting firms to support coordinated anti-corruption compliance projects taking into account the U.S. FCPA, UK Bribery Act, and France’s Loi Sapin II.
Assisted companies at various levels of compliance program maturity in either developing and implementing new compliance programs or updating existing compliance programs to account for enforcement developments, evolving guidance from key enforcement authorities, emerging best practices, and new anti-corruption laws.
Business and Human Rights and ESG
Advised U.S. importers on shipment detentions under the UFLPA and WROs, including by managing reviews of supply chain tracing documentation, preparing admissibility review submissions, and advising on related regulatory and commercial issues.
Advised companies in the technology, healthcare, apparel, and agri-business sectors on UFLPA enforcement risks and compliance strategies
Conducted a review of a major healthcare company’s responsible sourcing program and provided continuing advice on the development of the program and related legal risks.
Conducted human rights due diligence for an acquisition in the consumer goods sector and helped the client develop a mitigation strategy for supply chain risks, including by negotiating bespoke contractual provisions with the target and its manufacturing partner.
Advised a multinational technology company on an OECD National Contact Point proceeding involving alleged non-observance of the human rights and certain other provisions of the OECD Guidelines for Multinational Enterprises.
Assisted a European-headquartered energy company in conducting human rights due diligence in relation to a significant joint venture, negotiating related contractual provisions, and developing broader human rights due diligence procedures for M&A transactions.
Advised a range of companies on BHR and ESG due diligence programs and reporting consistent with best practice voluntary standards (including the UN Guiding Principles on Business and Human Rights), existing requirements (including the UK Modern Slavery Act), and emerging legal requirements across Europe.
Suspension and Debarment Matters
Advised a European engineering company on interactions with the World Bank’s Integrity Vice Presidency and Integrity Compliance Office, including by supporting several internal investigations into World Bank-financed projects and advising on the development of a corporate compliance program.
Advised a Southeast Asia-based energy company on interactions with the World Bank’s Integrity Vice Presidency in connection with an investigation into alleged fraudulent practices, including by conducting an investigation into the allegations and developing a compliance remediation plan.
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