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Welcome

Integrity and honesty are at the heart of everything we do.

We hold ourselves accountable to the highest ethical standards and we must each take personal responsibility for complying with anti-bribery and anti-corruption laws and policies. We do not tolerate bribery or corruption involving our people, agents, vendors or other business partners.

After completing this course you should:

Know the red flags of bribery and corruption and when to escalate

Identifying and escalating the red flags of bribery and corruption will help to protect the firm’s and your personal reputation.

Always remain vigilant

While the firm has a robust control framework, one of our best defenses against bribery and corruption remains the vigilance of our people and our collective commitment to doing the right thing.

Be thoughtful

Whether you’ve been at the firm for one day or thirty years – everyone needs to take this training regularly. Take the time to go through this module and be thoughtful in your responses.

What are Bribery and Corruption?

Select each button for definitions of bribery and corruption and relevant laws.

Select each button to learn more.

Bribery

Bribery involves improperly offering, paying, authorizing, promising, soliciting or receiving anything of value with the intent to improperly obtain or retain business, any business advantage or to influence a government or regulatory action.

‘Anything of value’ is a broad term that can include cash, gifts, travel and entertainment, event invitations, political contributions, charitable donations and offers of employment or internships.

Bribery can involve corrupt payments to public officials, employees of corporate clients or suppliers, and their relatives, friends, agents and associates, and other private parties.

‘Public officials’ is also a broad term and includes officers and employees of government entities (including state-owned enterprises), public international organizations and political parties, persons holding elected or appointed office (or candidates for political office) and any person exercising a public function or acting in an official capacity for any of the above.

Corruption

Corruption can take many forms and is any unlawful or improper behavior that seeks to gain an advantage through illegitimate means or abuse of power, whether in public or private office, for personal gain.

Anti-Bribery and Anti-Corruption Laws

Applicable anti-bribery and anti-corruption laws include:

  • U.S. Foreign Corrupt Practices Act (FCPA):
    Prohibits the payment of bribes to foreign officials to assist in obtaining or retaining business or any improper business advantage (the supply side of bribery), as well as requires the maintenance of accurate books and records.
  • U.S. Foreign Extortion Prevention Act (FEPA):
    Prohibits the demand or acceptance of bribes by foreign officials (the demand side of bribery).
  • U.K. Bribery Act (UKBA):
    Criminalizes bribery and receipt of bribes, the bribing of foreign government representatives, and the failure by private companies to prevent corruption.

Five Key Areas

The five main areas of heightened bribery and corruption risk are:

  1. Intermediaries/Finders
  2. High-Risk Vendors and Other Third Parties
  3. Relationship Candidates
  4. Gifts, Travel and Entertainment
  5. Political and Charitable Contributions

As you learn about each of these areas, pay careful attention to the red flags and situations where the heightened risk may not be so obvious.

You will be required to pass an assessment on these topics at the end of the module.

Did You Know…

Approximately 90% of all bribery enforcement actions have involved intermediaries/finders?

Define Intermediaries

Intermediaries are third parties who are engaged, whether formally/informally or directly/indirectly, by the firm or another party to provide services in connection with potential business opportunities (e.g., transactions, joint ventures, partnerships and other opportunities including client relationships).

A third party may be considered an Intermediary even if it is not compensated and even if the business opportunities do not materialize.

At the Core

What do you need to know about intermediaries?

Select each question to learn more.

Why do intermediaries pose heightened risk?

Intermediaries pose heightened risks to the firm because they act on behalf of the firm or other parties involved in firm business and can interact with private parties or public officials in connection with business opportunities.

What do I need to do if I am aware of intermediary involvement in a business opportunity?

If you become aware of a direct or indirect intermediary’s involvement in a business opportunity:

  • Immediately escalate to the Anti-Bribery & Corruption Group (AB&C) in Financial Crime Compliance for enhanced due diligence and other requirements.
  • Complete the Due Diligence Form for Intermediaries and Finders.
  • If AB&C approves a direct intermediary, ensure that there is a written contract in place with appropriate anti-bribery provisions.

Direct and Indirect Intermediaries

Let’s break down the differences between Direct and Indirect intermediaries.

Select each image button to learn more.

Direct Intermediaries

Third parties engaged and/or compensated by the firm to:

  • Find, introduce, identify, source or maintain business opportunities;
  • Interact with or introduce the firm to public officials or government entities related to a business opportunity; or
  • Satisfy a condition or requirement of a client, prospective client, public official or government entity in the firm’s involvement of a business opportunity.

‘Government entity’ refers to any office, agency, ministry, instrumentality, sovereign wealth fund, or other part of a national, regional, or local government, public international organization, or royal family.

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Indirect Intermediaries

Third parties engaged and/or compensated by a client, underwriting syndicate, co-investor, counterparty, acquisition target, or another non-firm party involved in a business opportunity with the firm to provide referral, introductory or advisory services.

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Certain third-party activities that take place in the ordinary course of the firm’s business may be excluded. For details, see the Firmwide Policy on Intermediaries/Finders.

Direct Intermediaries
Indirect Intermediaries

Time to Focus: Learn the Red Flags

Some of the common red flags are when the intermediary:

Does not have a defined role and will not provide any services in the transaction, but participates in, or facilitates, the firm’s business discussions with the client, public officials, or other parties

Is introduced or recommended by a public official or government entity in connection with a transaction

Requests payments to or retention of a public official (or their immediate family members or close associates) or a Politically Exposed Person (PEP)

The term ‘PEP’ includes an individual who is a current or former senior government official, or a close associate or immediate family member of the same

See the Firmwide Policy on Intermediaries/Finders for the full definition

Refuses to include the firm’s standard anti-bribery provisions into the contract covering the intermediary arrangement

Is located and/or operating in a high-risk jurisdiction as set out in the Firmwide Annex on Country Lists

Will receive unusually high fees or other compensation/benefits

Provides an invoice that appears falsified or with inflated amounts, or has duplicative or vague descriptions of services

Has no identifiable media profile                            

Appears unqualified for the services being provided

For a full list of red flags, including those related to transactions, review the Firmwide Policy on Intermediaries/Finders.

Requirements

The Firmwide Procedures for Significant and Complex Transactions — ("SCTs") — describe the SCT governance and diligence processes related to SCTs and call attention to red flags of bribery and corruption.

All Intermediaries (Direct or Indirect) must be (i) disclosed in the SCT Memorandum and DDQ and (ii) escalated to Compliance for further review.

Did You Know…

The firm currently has over 9,300 vendor relationships?

At the Core

What do you need to know about the bribery and corruption risks presented by vendors?

Select the arrow button to find out more.

Your Responsibilities

You should know if your vendor is considered high-risk from a bribery and corruption perspective.

You must receive pre-approval from AB&C before engaging any high-risk vendors and executing contracts with those vendors.

All Vendor Relationship Owners (VROs) are responsible for onboarding their vendors to the “Know Your Third Party” (KY3P) system prior to commencing work and should have oversight of vendors’ activities at all times.

 

High-Risk Vendors

High-risk vendors include, but are not limited to those:

  • Located or operating in high-risk jurisdictions
  • With authority to make or receive payments on behalf of Goldman Sachs
  • Responsible for obtaining/maintaining licenses, permits or other government approvals on behalf of Goldman Sachs
  • Recommended to the firm by a public official or government entity
 

Vendor Responsibilities

All vendors and their subcontractors should know and follow our Vendor Code of Conduct.

Third parties, including intermediaries and vendors are strictly prohibited from making or routing corrupt or improper payments, which include facilitation (“grease”) payments (i.e., payments made to public officials--not government entities--to facilitate or expedite a routine government action or an administrative process).

 

Role of AB&C

AB&C conducts due diligence on high-risk vendors and negative media screening of all vendors onboarded to KY3P.

 
 
 

Time to Focus: Learn the Red Flags

Some of the common red flags are when the vendor or other third party:

Is managed, owned or controlled by public officials

Provides entertainment to public officials              

Charges unusually high or unexplained fees              

Has been the subject of negative media or allegations that suggest fraud, bribery or other financial crime risks

Is located in or operating in high-risk jurisdictions

Obtains licenses, permits or other government approvals on behalf of the firm

Is recommended to the firm by a public official or government entity

Did You Know…

A financial institution paid $264 million to settle charges that it employed well-connected Chinese “princelings” – children of government officials – in order to win business.

Overview

The firm welcomes and considers all qualified candidates for positions of employment, regardless of their connections. However, we have strict rules when it comes to hiring "Relationship Candidates."

What is a Relationship Candidate?

This term refers to any job applicant who is referred by or closely connected to:

  • Current or potential clients
  • Public officials (including employees of government or regulatory agencies)

Which positions are Covered?

  • Full-time or part-time employment
  • Paid or unpaid internships
  • Training or "exploratory" programs
  • Consulting or contract work
  • Work shadows: This is a one-day opportunity for students to observe a GS professional at the firm

At the Core

What do you need to know about relationship candidates?

Select each button to learn more.

Immediately Escalate

You should immediately flag Relationship Candidates to HCM, which will escalate them to AB&C for review and approval before an offer is extended.

These requirements apply even if you have a personal relationship with the candidate or the external party referring the candidate.

No Promises

You must not offer or promise a position of employment, including an internship or work shadow, to obtain or retain business, gain an inappropriate business advantage, influence government or regulatory actions.

Merit-Based Process

The hiring process, including interviews, must always be merit-based.

Post-Hire Restrictions

Once Relationship Candidates join the firm, post-hire restrictions (known as “ring-fencing”) may be imposed to mitigate potential bribery risk.

For example, the ring-fenced employee would be prohibited from any business-related solicitation or communication with the external connection (i.e., individual and/or entity), which may include family members or other connected persons such as external referrers and their companies.

Time to Focus: Learn the Red Flags

Some of the common red flags for Relationship Candidates are when:

An external party who refers a candidate recommends the Relationship Candidate on an email chain regarding a pending business transaction or potential opportunity

A GS employee who refers the Relationship Candidate (internal referrer) wants to hire the candidate despite relatively weak qualifications or negative interview feedback

Internal or external parties indicate the importance of a client or the potential benefits to the firm if the Relationship Candidate is hired/interviewed

A GS employee contacts interviewers and alerts them to the Relationship Candidate’s connection to a client, in an attempt to influence the candidate’s hiring process

A GS employee puts pressure on HCM for updates or excessively coaches the Relationship Candidate (e.g., editing resume, providing tips on specific interview questions, and/or offering multiple prep sessions or multiple introductions to firm personnel compared to non-Relationship Candidates)

The firm appears to create a position specifically for the Relationship Candidate

The internal referrer arranges interviews for a Relationship Candidate outside of the firm’s standard HCM recruiting process

Review the requirements set out under the Firmwide Policy on Relationship Candidates for more details.

Dig Deeper

Select the policy to learn more.

Firmwide Policy on Relationship Candidates

Think about it…

Offering gifts, travel and entertainment is often helpful in strengthening business relationships, but such benefits must be transparent, business-related, and appropriate.

“Lavish” or excessive gifts, travel and entertainment may improperly influence the recipient’s business judgment or create the appearance that the firm is trying to obtain or retain business in exchange for these benefits, which may violate anti-bribery and anti-corruption laws.

Pay close attention to your business offerings, receipts and expenses, using good judgment and considering the reputation of the firm.

You should not accept gifts, travel or entertainment that are lavish or so frequent that they may suggest impropriety.

At the Core

What do you need to know about gifts, travel and entertainment? Follow these “Do’s” and “Don’ts”.

Do

Submit pre-approval requests in Concur for:

  • Any gift for a client or third party.
  • Any travel or entertainment for "Restricted Recipients," no matter how much it costs.
  • Any travel or entertainment for other clients or third parties (including ticketed events) that you expect will cost more than $250 per person.

Who are "Restricted Recipients"?
Public officials (including employees of state-owned entities and public pension funds, officials of supranational organizations and political parties), employees of exchanges, regulators, examiners, as well as ERISA fiduciaries.

If you are not sure about the client’s restriction status, you can check REPS, which is the firm’s tool for creating and maintaining third-party profiles.

Recordkeeping
Accurately report the total value of all gifts, travel and entertainment in Concur in a timely manner, even if part or all of the expense is paid with personal funds and you are not seeking reimbursement.

Only request reimbursement for valid business expenses. You are expected to carefully review your own expenses, even if the reports are prepared by others on your behalf.

Receiving
If you receive a gift worth more than US$100, or travel/entertainment worth more than US$250 from a client or another third party, you must seek approval through the Receipt of G&E Tool.

Keep in mind that some departments and regions may have stricter limits. If you have any doubts, ask your Compliance contact whether additional rules apply to you.

Don't

Offer, promise or authorize gifts, travel or entertainment to improperly influence government or regulatory action, or to obtain or maintain business or an improper business advantage.


Inappropriate expensing, inaccurate reporting or improper offering of gifts, travel or entertainment will result in disciplinary action.

Time to Focus: Learn the Red Flags

Some of the common red flags for gifts, travel and entertainment are:

Excessive entertainment of a single individual who is a key client decision-maker

Entertaining a Restricted Recipient without seeking pre-approval

Charging inappropriate personal expenses to client projects

Inviting a current or prospective client to a potentially lavish event ahead of a non-routine deal pitch

“Topping off” (i.e., failing to report the full value of gift, travel or entertainment provided by absorbing the excess amounts from personal funds)

Adding attendees to a Concur request to reduce the per-person cost

Review the core principles of the Firmwide Policy on Gifts, Travel and Entertainment for more details.

Think about it…

Under certain circumstances, political or charitable activities can present elevated bribery and corruption risks, or at least raise appearance issues.

Overview

Charitable contributions, including to bona fide charities, must never be made if the intent or effect is to improperly influence the business judgment of any person, including a public official, client, potential client, or influence government or regulatory action.

The rules with respect to political activities are complex and vary by jurisdiction with severe penalties for violations.

So, if you are unsure – ask questions and seek guidance from Compliance.

At the Core

What do you need to know about political and charitable contributions?

Select each image button to learn more.

Never Solicit Contributions for Improper Purposes

Never make or solicit a political or charitable contribution or engage in political or charitable activity to obtain or retain business or a business advantage from any person, including a client, potential client, public official or anyone connected to a government entity, or to influence government or regulatory action.

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Be Aware of Appearances

Even contributions to bona fide charities may create the appearance of potential bribery or corruption, if linked to firm business or a government or regulatory action.

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Seek Pre-Approval

Certain business-related charitable contributions, such as those related to public officials or government entities, high-risk jurisdictions, or pending non-routine business, must be pre-approved by AB&C.

The firm also requires pre-approval before GS employees (in certain jurisdictions, and in some cases their spouses and dependents) make political contributions or otherwise engage in political activity.

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Never Solicit Contributions for Improper Purposes
Be Aware of Appearances
Seek Pre-Approval

Time to Focus: Learn the Red Flags

Some of the common red flags for charitable contributions include:

A public official requesting or otherwise associated with a contribution

Donation solicited by or directed to a jurisdiction known to be high-risk for bribery and corruption

Communications that suggest the awarding, retention or contracting of business is dependent on making a contribution

Pending non-routine business with the client requesting contribution

Lack of transparency around the bank account for the charitable recipient

Request for a contribution to be made anonymously or secretly

Review the Firmwide Policy on Charitable Contributions for a full list of red flags.

Before You Go…

It’s almost time to test what you have learned in this training. But before you go, let’s take a moment to reinforce the key takeaways of this training.

Select the arrow button to find out more.

Protect the Firm and Ourselves

Bribery and corruption continue to be a focus for the firm and for our regulators globally. We must protect the firm and ourselves by complying with anti-bribery and anti-corruption laws and internal policies.

 

No Retaliation

We do not tolerate bribery or corruption involving our people, vendors, agents or business partners. Our Business Integrity Program (BIP) offers numerous channels for our people to escalate concerns, without fear of reprisal.

 

A Manager’s Role

Managers play a critical role in setting the tone for our people, in upholding our core value of integrity, and maintaining the highest ethical standards in all that they do.

 

Our Collective Responsibility

We have a collective responsibility to uphold the firm’s standards of integrity and ethics as stated in the firm’s Code of Business Conduct and Ethics.

 

Here to Help

AB&C in Financial Crime Compliance is your main point of contact, and you must immediately escalate if anyone solicits bribes, kickbacks, improper payments, gifts, or other benefits or advantages from you. You must also escalate if you become aware of any red flags or violation of the Goldman Sachs Anti-Bribery & Anti-Corruption Compliance Statement or the firm’s anti-bribery policies by our people, vendors, agents or business partners.

Remember: You are the firm’s best defense against bribery and corruption!

 
 
 

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Michel, a VP in AWM Private, is looking for new real estate opportunities in the housing sector in Turkey. Michel wishes to engage a consultancy firm with local industry experience operating in Turkey, to present potential acquisition targets for GS.

The consultancy firm has a wide network in the market, including rumored close connections with public officials who will be approving the acquisitions related to government housing assets. During diligence review, Michel learned that the managing partner of the consultancy firm has faced allegations of bid-rigging related to housing projects.

Which one of the following is NOT a red flag for bribery and corruption risk in this situation? Read the options carefully.

Select the option you think is correct and then select Submit.

Please only use the tab and shift tab keys to access each option and the Submit button with the keyboard. Then only use the Enter or Space key to select an option or the Submit button with the keyboard. The up and down arrow keys are not fully supported. If the screen reader suggests that you use the arrow keys to change an option, please ignore this. Continue using the tab and shift tab keys and then Enter or Space keys to change an option. If you stop hearing the screen reader use the tab key to reset the focus.

Geoff, an MD in GBM Private, receives an email from the CFO of a client, a fintech company based in Hong Kong, with which the firm is in midst of potential financing discussions. The CFO asks Geoff if there are any opportunities for internships at the firm for his daughter. Geoff knows that the deadline for the current cycle has closed and that positions have been filled but tells the CFO that he will see if any additional headcount can be found. Without consulting GMB Private management, Geoff subsequently informs the CFO that he has found additional headcount for the position. In parallel, Geoff starts to coach the daughter with specific interview questions and arranges for her to be interviewed, highlighting to those interviewers the potential revenue from the client relationship.

Which of the following are red flags for bribery risk in this situation? Remember to read the options carefully.

Possible red flags:

  1. Geoff creates additional headcount for the position.
  2. Geoff excessively coaches the client’s daughter and highlights to interviewers the importance of the client relationship.
  3. There are pending business discussions with the client which may present potential bribery risk.

Select the option you think is correct and then select Submit.

Please only use the tab and shift tab keys to access each option and the Submit button with the keyboard. Then only use the Enter or Space key to select an option or the Submit button with the keyboard. The up and down arrow keys are not fully supported. If the screen reader suggests that you use the arrow keys to change an option, please ignore this. Continue using the tab and shift tab keys and then Enter or Space keys to change an option. If you stop hearing the screen reader use the tab key to reset the focus.

Laura, a VP in AWM Public, receives an email from the CIO of a state university in the U.S. which is looking for a bank to manage its endowment. The firm was asked to submit a request for proposal (RFP) against other banks in a competitive bidding process.

The CIO reaches out to Laura to seek a charitable contribution from the firm for the development of a new sports facility at the university and implies that the RFP decision will be conditional upon the firm making a sizeable charitable donation.

Why should this request be escalated to Compliance?

Select the option you think is correct and then select Submit.

Please only use the tab and shift tab keys to access each option and the Submit button with the keyboard. Then only use the Enter or Space key to select an option or the Submit button with the keyboard. The up and down arrow keys are not fully supported. If the screen reader suggests that you use the arrow keys to change an option, please ignore this. Continue using the tab and shift tab keys and then Enter or Space keys to change an option. If you stop hearing the screen reader use the tab key to reset the focus.

Yan in GBM Public is arranging an offsite event with a small group of key senior representatives from a Saudi sovereign wealth fund (SWF) to discuss potential business opportunities. Before submitting a pre-approval request in Concur, she books an exclusive high-end resort and lines up an agenda with both educational topics and recreational activities. During the weekend trip, the SWF representatives use the spa, which is not one of the pre-agreed recreational activities, and charge it to the firm.

What should Yan have done in this scenario? Remember to read the options carefully.

  1. Yan should have submitted a pre-approval request in Concur for the gifts, travel and entertainment proposed to be offered at the event, as the SWF representatives are Restricted Recipients (e.g., public officials, employees of a government entity).
  2. Yan should have escalated the spa charges to Compliance as these are additional activities not pre-approved by the firm.
  3. Yan should not have hosted an offsite event.

Select the option you think is correct and then select Submit.

Please only use the tab and shift tab keys to access each option and the Submit button with the keyboard. Then only use the Enter or Space key to select an option or the Submit button with the keyboard. The up and down arrow keys are not fully supported. If the screen reader suggests that you use the arrow keys to change an option, please ignore this. Continue using the tab and shift tab keys and then Enter or Space keys to change an option. If you stop hearing the screen reader use the tab key to reset the focus.

Both GBM Private and GBM Public are working on a bond offering for the Government of Peru, with the proceeds to be used to fund specific renewable energy projects, which will be reviewed and approved by the Government.

During the course of the transaction, the teams become aware that the Government of Peru has retained a local consultant. The consultant, who has limited profile and no track record, will be responsible for advising the Government of Peru on the selection of banks involved and which projects will be funded from the bond offering.

Should this be escalated to Compliance?

Select the option you think is correct and then select Submit.

Please only use the tab and shift tab keys to access each option and the Submit button with the keyboard. Then only use the Enter or Space key to select an option or the Submit button with the keyboard. The up and down arrow keys are not fully supported. If the screen reader suggests that you use the arrow keys to change an option, please ignore this. Continue using the tab and shift tab keys and then Enter or Space keys to change an option. If you stop hearing the screen reader use the tab key to reset the focus.

Attestation

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FCC Anti-Bribery and Anti-Corruption Training 2026
 

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