Following the data where others couldn’t

A specialized KPMG team brings forensic risk assessment and data analytics to an internal bribery investigation.

Client

A global pharmaceutical company

Industry

Healthcare and life sciences

Primary goal

Analyze internal company database to assess bribery allegations

Methodology

Gather, structure, and apply data analytics to identify red flag events in company records

 


When a major pharmaceutical company faced internal allegations that employees in its Russian office had facilitated bribes through third-party event organizers, senior management recognized the seriousness of the threat and acted quickly. They asked KPMG LLP (KPMG) to help the company’s outside legal counsel investigate the allegations by conducting an in-depth analysis of transactions, events, and other records.

We mounted a specialized, cross-functional team combining healthcare industry knowledge, forensic accounting skills, and industry-leading data analytics capabilities from the KPMG Lighthouse Center of Excellence. Even as sanctions imposed on Russia after its invasion of Ukraine made access and analysis more difficult, we uncovered data to support or refute existing claims and guide the client and outside counsel in real time. While the matter has yet to be resolved, KPMG has already helped protect the client from further action and potential penalties by acting as a trusted, qualified, and objective adviser.
 

Key outcomes

32

risk events analyzed after initial review by outside counsel

66

total high-risk events uncovered via applied risk weighting

Improved protection

and compliance after a thorough, objective investigation

 

Client transformation journey

Click on each part of the journey to learn more about our client’s transformation.

 
  • Where they were
  • Where they are
  • Where they’re headed

Where they were

Looking for the “one way” forward after acquisition-fueled growth.

Albertsons is committed to “one way.” Meaning that, as large as the company becomes, it aims to remain unified in its vision and in the systems and tools that support it. 

Acquisition-fueled growth naturally opens the door to “many ways.” By 2019, different divisions and subsidiaries had their own back-office solutions. People, processes, and data were becoming more siloed.

A different kind of company might have assumed that decentralized processes are an acceptable consequence of multiple acquisitions. Or that you can’t be one of the biggest industry players and move with startling speed and agility when it comes to acquisitions. But accepting trade-offs like those is not the Albertsons way.

Company-wide opportunities

  • Replace nearly XX aging applications that differed across divisions and subsidiaries
  • Reduce manual, disparate processes freeing up more resources for advanced analytics
  • Enable enhanced reporting and make it more widely available across the enterprise
  • Act with greater speed and agility to capture value in acquisitions

Finance Opportunities

  • Process XXX,XXX transactions per month with greater efficiency
  • Reduce 10,000+ manual journal entries per period
  • Decrease >3-week close
  • Shorten the >3-month annual budgeting cycle
  • Provide better support for a growing e-commerce busines
  • Control rising finance function costs and derive greater value 

HR Opportunities

  • Decrease hiring and onboarding times to keep pace with staffing needs
  • Be more efficient in complying with more than 800 collective bargaining agreements and dozens of government contracts
  • Introduce enterprise-wide training programs
  • Unify and automate workforce administration processes across the enterprise

Where they are

290,000+ Albertsons employees come together every day in the cloud.

Today, cashiers at 2,200 stores all log their hours via the same mobile app. That data flows seamlessly to payroll, and across the enterprise-- where it’s available for everyone from store managers making data-driven staffing projections to CFOs reviewing budgets.

Back-office staff spend less time on manual processes and more on analyzing data in ways that help lower costs and improve performance every day, and inform due diligence during acquisitions.

HR executives and business managers find it easy to access candidate information, share observations and schedule interviews, quickly and easily moving the right candidates through the hiring process.

And candidates who become new hires, continue through the same efficient, cloud-based environment as they complete onboarding and get to work—already a part of Albertsons’ “one way.” 

Company-wide success

  • Installed a single, modernized digital platform serving the entire enterprise
  • Accelerated the project schedule by XX-months due to a dual-installation of Finance and HR
  • Migrated 290,000 employees from legacy systems to Oracle Cloud
  • Increased insight-driven decision making across functions, driving performance and growth gains

Finance Successes

  • Decreased balance sheet reconciliations by 85%
  • Achieved a consolidated retail and corporate close within a shortened period
  • Reduced the types of P&L statements from 100+ to 4
  • Reduced operations costs across the board
  • Enhanced availability of data-driven insights that help to capture maximum value during acquisitions

HR Successes

  • Installed an automated, central solution to efficiently administer 800+ complex union agreements for all employee populations
  • Deployed a custom application for union rule processing enabling a single HCM platform to administer benefits to all employee populations
  • Created a digital-first, digital anywhere experience resulting in higher employee engagement
  • Reduced new hire onboarding time
  • Reduced the time it takes to fill staffing vacancies
  • Streamlined and improved the process integration of new employees post-acquisition
  • Integrate processes and technology across the employee lifecycle from recruiting through compensation and performance

Where they’re headed

Making sure the “one way” continues to be the best way.

Long before the go-live date, Albertsons was collaborating with Oracle and KPMG about future initiatives. They wanted to know what to expect from upcoming product releases and how they should be planning to leverage new functionality.

The company’s agile mindset combined with its investment in Oracle Cloud and KPMG Powered Enterprise will keep it in a position to continue evolving, always finding the best way forward as one, strong enterprise.

Company-wide vision
  • Continue to enhance analytics-driven planning and forecasting
  • Optimize the supply chain

Finance Vision

  • Achieve a continuous, virtual accounting close
  • Increase data monetization 

HR Vision

  • Migrate payroll, benefits, and absence mangement to Oracle cloud for 2023
  • Insource benefits administration

“It is tough for consulting firms to separate themselves from their competitors in this market, as everyone has great talent and resources. Your excellent work in making KPMG so easy to do business with is truly a differentiator that separates KPMG from the rest of the pack and definitely influences our decisions on selecting a firm for particular projects.” 

- In-house counsel, KPMG client company

 

KPMG unlocks value from data in a uniquely challenging environment

     
     
     
     
     
     
     
     

1. Assessment phase


Bringing order to unstructured data

Gaining access to the client’s data proved to be a significant challenge in itself. In March 2022, KPMG stopped working with its Russian firm after the start of the Russia-Ukraine war. Not only were we unable to draw on our usual local resources, but new regulations made it impossible to access data directly from companies based in Russia. But since the relevant databases were actually stored on servers located in Europe, our team was able to work around this constraint.

Our first step was to gather, clean, and structure Structured Query Language (SQL) data from the client’s system records. We then performed an exploratory data analysis to gain a better understanding of its structure, elements, and relevant event characteristics.

Data analysts from the KPMG Lighthouse team played a critical role by reworking unstructured data to make it more understandable and usable, both to our own life science compliance specialists and the client’s outside counsel.

2. Analysis phase


Applying analytics to anomalies

We began this stage by developing hypotheses for analyzing the data and applying models to validate them. These included a series of risk-weighted analytics that were used to test the hypotheses.

Then, working from the assembled SQL database and local compliance event spreadsheets, we performed trend and outlier analysis to identify potential irregularities in the event processes, parties, and fields that could require a deeper dive or red flag identification. Examples included:

•       Anomalies between the various event populations provided, such as missing events, missing fields, or conflicting key fields

•       Anomalies around event costs or counts based on key fields associated with the allegation, such as irregularities in average event costs by type, business unit, business owner, organizer, and participants.

We also performed a trend analysis of anomalous activity by parties cited in the allegations, including HCOs, doctors, other HCPs, and other third-party businesses and individuals.

Finally, to support our findings we conducted a follow-up technical analysis of invoices, payments, contracts, and other documentation. 

3. Reporting phase


Uncovering new risks, meeting new deadlines

Throughout our analysis, the KPMG team delivered real-time reporting on our progress and results to help guide the ongoing legal investigation. Our findings were reported to outside counsel and the client to enable review of higher-risk transactions and their associated risk factors and to identify next steps on document review or witness interviews.

Along with our analysis of risk events or anomalies initially targeted by outside counsel, we also uncovered new higher-risk events based on our own risk rating and scoring methodology. These included monetary inconsistencies, control variations, and other red flags derived from analysis of specific allegations. By applying additional risk weighting to an original base of 32 events under review, we more than doubled that figure to 66 higher-risk events or transactions.

The issue of access to data returned suddenly when new legislation barred the removal of data pertaining to any individual working in Russia after September 30, 2022. At this point, the investigation team had identified five hard drives within the country that needed to be imaged. To find a way to do this before the new deadline, the client approached other major accounting firms, none of which were ready to take on the challenge. But after close study and quick response by KPMG Advisory leadership and the client’s outside counsel, we concluded that gathering the data would be both possible and legal. Our recommendation ultimately led the client to work through a smaller firm within Russia, but without the help of this smaller firm, this critical evidence could have been lost.

At another level, our ability to deliver valuable analysis on a tight schedule helped the client demonstrate that its internal investigation was backed by an objective, qualified third party. KPMG also supported the client by offering control recommendations and improving their current existing compliance monitoring practices to avoid future allegations.

4. Evolution phase


Lessons learned from a versatile team

While the legal investigation continues, our compliance and forensic risk assessment work on the case is complete. But the same KPMG team is still helping the client assess allegations related to bribery and corruption in other countries. As in the Russia investigation, our ability to mount a cross-functional team with in-depth knowledge of healthcare, compliance, and data analytics has proven invaluable, along with our willingness to act quickly and take every step needed to deliver results for the client and its legal team.

 

Turning threats into opportunities

Our work in Russia is just one example of how KPMG is using the power of advanced data analytics to help healthcare and life sciences companies manage risk and protect themselves from legal action or penalties. Learn more about our Risk and Compliance Services and our KPMG Lighthouse data analytics center of excellence.

  
 

Transform the way you manage risk and compliance

Let’s talk about where you are now and your goals for the future. 

Matthew McFillin

Matthew McFillin

Partner, Forensic Services, KPMG US

+1 267-256-2647
Lauren Polana

Lauren Polana

Director Advisory, Forensic, KPMG US

+1 267-256-3209