Home Compliance Andy Spalding: The Pilot Program as Declination Policy ComplianceExpert OpinionNews Andy Spalding: The Pilot Program as Declination Policy September 20, 2017 18 Share FacebookLinkedinTwitter You must be a Paid or Free Trial Member to Access this Content. Paid members, please login to view your news subscription(s). RELATED ARTICLESMORE FROM AUTHOR Compliance The FCPA Turns 47 Compliance The Holidays: Time to Kickback and Relax? Compliance Another FCPA Enforcement Action Related To South Africa’s Broad-Based Black Economic Empowerment Program