About

Team size: 14
Major law firms used: Allen & Overy, Akin Gump Strauss Hauer & Feld, Freshfields Bruckhaus Deringer, Latham & Watkins, Linklaters, Ropes & Gray

Anti-bribery and corruption regulations have been front of mind for global alternative asset manager The Carlyle Group, which has $212bn of assets under management. Global GC for investments and head of Europe, Heather Mitchell, says the London-based legal team recently pioneered a project with Ropes & Gray looking at how the private equity firm addresses anti-bribery and corruption globally.

By getting one firm to do all of this work, whether it be an oil and gas deal in Africa or a technology deal in the Philippines, Carlyle knows there will be a consistent approach to assessing risk. The group’s entire global portfolio is then assessed every six months from an anti-bribery and corruption perspective. ‘We rank all of our current and historical portfolio companies on whether they are high, medium or low risk,’ Mitchell says. ‘Some companies – given certain sectors and/or geographies – will never be a low risk, no matter what policies or efficiencies we put in place, but the goal is to not have anything high risk.’

Mitchell says Carlyle has also been rolling out more questionnaires to its portfolio companies and has implemented a new cyber security risk analysis tool. The overall objective is to improve knowledge about potential acquisitions ahead of time, rather than discovering various risks after the fact.

Her legal team is split between four lawyers in the UK, and three in each of Asia and the US, alongside a couple of trainees across the regions. The team is rolling out more training to help the legal function strike a balance between commerciality and bureaucracy. ‘We’re trying to put in practices that take bureaucracy away from the team. We need to be nimble and commercial – that’s our business.’

Linklaters partner Alex Woodward comments: ‘She is very good at managing the team across all the different investments and things they have as a house, which given the size and scale of Carlyle is no mean feat.’