Anti Bribery and Corruption

What is Bribery and Corruption?

Corruption is the abuse of power – or the inducement to abuse power – for personal, political, or commercial gain. It’s often done in secret. Bribery is a specific offense that involves the exchange of something that has value to the receiver.But… it’s given in the hope of getting something in return. Its impact on society is damaging, and it’s more common than you might think. Corrupt activity, bribery, or attempted bribery is never acceptable for legal, moral, and ethical reasons. Each and every one of us has a responsibility to ensure that all our business relationships are conducted in an ethical and honest manner.
Failure to do so harms society, our company, your colleagues, and you. You need to be able to recognize red flags for bribery and corruption, so you can protect our company, your colleagues, and yourself.

Emily and the Government Official

Emily spends time with a foreign government official while researching a location for a new office. To show her appreciation, Emily wants to take the official and his entire team to a gourmet restaurant.

How would you advise Emily?

  • Don’t do it without contacting Legal first. This offer could be considered a violation of the anti-bribery and corruption laws.
  • It’s reasonable to expense a business dinner. This would not be considered a violation of the anti-bribery and corruption laws.
  • It’s important to keep positive relationships with local officials. Treating the government official and his team to dinner is an appropriate way to say “thank you.”

Business dinners may be appropriate, but if dinner is outside the guidelines and could be considered extravagant, it may be perceived as an attempt to improperly influence decisions to be made by government officials. If you are ever unsure as to whether or not you can offer hospitality, you can find out who to contact for clarification here. Ask yourself, do you feel you could recognize when a situation could compromise your or our company? Do you know when and how to escalate this type of issue?

Emily and the Government Official

During a meeting one of the government official’s team says: “My uncle is hosting a fundraising dinner for a local charity. The cost is five thousand dollars per plate. You should get to know my uncle; you might need his advice.”

How should Emily respond?

  •  Thank you. Our company is involved in charitable work, but I need to contact Legal to find out if my attendance would be appropriate.
  •  Thank you. I’ll see who else might be interested. It will be a good opportunity for us to meet your uncle; his advice could be very useful.
  •  Yes, I’ll send the contribution and email you the details. I need to copy my Legal department in on my email.

Thanks for helping Emily

Emily is now better prepared to recognize situations that could potentially involve bribery or corruption.
Remember, if you are ever unsure of what action to take, you can find out who you need to contact here, before making a decision.
It is your responsibility to know what type of situations you need to escalate, and who you need to escalate to.

This content is an extract from the ANTI BRIBERY, AND CORRUPTION training program.

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