Getting Started
How well do you know bribery and corruption risk?
We appreciate your honesty. Over the next few topics, we’re going to explore bribery and corruption risk in detail. You will be asked to answer a question on each of the bribery risk areas, and at the end, you can compare your results to the knowledge level you selected here.
We appreciate your honesty. Over the next few topics, we’re going to explore bribery and corruption risk in detail. You will be asked to answer a question on each of the bribery risk areas, and at the end, you can compare your results to the knowledge level you selected here.
We appreciate your honesty. Over the next few topics, we’re going to explore bribery and corruption risk in detail. You will be asked to answer a question on each of the bribery risk areas, and at the end, you can compare your results to the knowledge level you selected here.
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Five Key Areas
Learning Objectives
Bribery Risk: Intermediaries
Direct and Indirect Intermediaries
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 (Review to advance) 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.
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.
Time to Focus: Learn the Red Flags
There is a hotword ahead that needs to be reviewed to continue.
For a full list of red flags, including those related to transactions, review the Firmwide Policy on Intermediaries/Finders.
Put it into Practice
That's correct.
Red flags for this situation are that the business opportunity is located in the UAE, a high-risk jurisdiction, a third party facilitated an introduction to a government official, and the transaction requires government approval, which creates an opportunity for a bribe. The third party being a former Goldman Sachs MD, known to have improper conduct history, is also a red flag.
The deal team should escalate the former MD as a potential intermediary to the Anti-Bribery Group. Our policy defines intermediaries to include third parties formally or informally engaged, even if not compensated, to introduce a business opportunity.
That's incorrect.
Red flags for this situation are that the business opportunity is located in the UAE, a high-risk jurisdiction, a third party facilitated an introduction to a government official, and the transaction requires government approval, which creates an opportunity for a bribe. The third party being a former Goldman Sachs MD, known to have improper conduct history, is also a red flag.
The deal team should escalate the former MD as a potential intermediary to the Anti-Bribery Group. Our policy defines intermediaries to include third parties formally or informally engaged, even if not compensated, to introduce a business opportunity.
That's incorrect.
Red flags for this situation are that the business opportunity is located in the UAE, a high-risk jurisdiction, a third party facilitated an introduction to a government official, and the transaction requires government approval, which creates an opportunity for a bribe. The third party being a former Goldman Sachs MD, known to have improper conduct history, is also a red flag.
The deal team should escalate the former MD as a potential intermediary to the Anti-Bribery Group. Our policy defines intermediaries to include third parties formally or informally engaged, even if not compensated, to introduce a business opportunity.
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Case Study: Significant and Complex Transaction
Dig Deeper
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Bribery Risk: Vendors and Other Third Parties
At the Core
Time to Focus: Learn the Red Flags
Put it into Practice
That's correct.
Red flags for this situation were that the vendor charged an unusually high fee, which combined with the fact that vendor was recommended by a local politician and was not subject to a competitive standard vendor bidding process, means there is a high possibility that this could be a corrupt payment. Japan is a low-risk jurisdiction and therefore is not a red flag; however, this does not rule out potential bribery risk.
That's incorrect.
Red flags for this situation were that the vendor charged an unusually high fee, which combined with the fact that vendor was recommended by a local politician and was not subject to a competitive standard vendor bidding process, means there is a high possibility that this could be a corrupt payment. Japan is a low-risk jurisdiction and therefore is not a red flag; however, this does not rule out potential bribery risk.
That's incorrect.
Red flags for this situation were that the vendor charged an unusually high fee, which combined with the fact that vendor was recommended by a local politician and was not subject to a competitive standard vendor bidding process, means there is a high possibility that this could be a corrupt payment. Japan is a low-risk jurisdiction and therefore is not a red flag; however, this does not rule out potential bribery risk.
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Bribery Risk: Relationship Candidates
There are 2 hotwords ahead that need to be reviewed to continue.
Time to Focus: Learn the Red Flags
Review the requirements set out under the Firmwide Policy on Relationship Candidates for more details.
Put it into Practice
That's correct.
Red flags for this situation were that the PMD agreed to the work shadow without escalating to HCM or seeking approval from Anti-Bribery Group in Compliance. The PMD, knowing that there are pending business opportunity discussions, also excessively coached the client’s daughter and may have tried to influence the hiring process by contacting the interviewers and alerting them to the importance of the client relationship.
The client requesting a work shadow for his daughter in and of itself is not a red flag. However, all work shadows are considered Positions of Employment under the Policy and require review and pre-approval by the Anti-Bribery Group. If you are uncertain whether a visit constitutes a ‘work shadow,’ you should consult the Anti-Bribery Group before agreeing to it.
The PMD’s excessive coaching and outreach to the interviewers/HCM could create an appearance that the acceptance or consideration of a candidate is linked to the firm’s retaining or being awarded business. Such communications can cause the firm to reject otherwise qualified candidates.
That's incorrect.
Red flags for this situation were that the PMD agreed to the work shadow without escalating to HCM or seeking approval from Anti-Bribery Group in Compliance. The PMD, knowing that there are pending business opportunity discussions, also excessively coached the client’s daughter and may have tried to influence the hiring process by contacting the interviewers and alerting them to the importance of the client relationship.
The client requesting a work shadow for his daughter in and of itself is not a red flag. However, all work shadows are considered Positions of Employment under the Policy and require review and pre-approval by the Anti-Bribery Group. If you are uncertain whether a visit constitutes a ‘work shadow,’ you should consult the Anti-Bribery Group before agreeing to it.
The PMD’s excessive coaching and outreach to the interviewers/HCM could create an appearance that the acceptance or consideration of a candidate is linked to the firm’s retaining or being awarded business. Such communications can cause the firm to reject otherwise qualified candidates.
That's incorrect.
Red flags for this situation were that the PMD agreed to the work shadow without escalating to HCM or seeking approval from Anti-Bribery Group in Compliance. The PMD, knowing that there are pending business opportunity discussions, also excessively coached the client’s daughter and may have tried to influence the hiring process by contacting the interviewers and alerting them to the importance of the client relationship.
The client requesting a work shadow for his daughter in and of itself is not a red flag. However, all work shadows are considered Positions of Employment under the Policy and require review and pre-approval by the Anti-Bribery Group. If you are uncertain whether a visit constitutes a ‘work shadow,’ you should consult the Anti-Bribery Group before agreeing to it.
The PMD’s excessive coaching and outreach to the interviewers/HCM could create an appearance that the acceptance or consideration of a candidate is linked to the firm’s retaining or being awarded business. Such communications can cause the firm to reject otherwise qualified candidates.
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Dig Deeper
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Bribery Risk: Gifts, Travel and Entertainment
At the Core
| Do | Do not | |
|---|---|---|
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Submit pre-approval requests in Concur for:
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Offer, promise or authorize gifts, travel and entertainment to improperly influence government or regulatory action, to obtain or maintain business or an improper business advantage. |
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Accurately report and record 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. |
Accept gifts from third parties with which the firm has a business relationship (other than gifts whose value is US$100 or less) without approval via the firm’s Receipt of G&E Tool. Any travel or entertainment greater than US$250 (or respective regional or divisional limits) must be submitted through the tool for additional review. |
|
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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. |
Time to Focus: Learn the Red Flags
Review the core principles of the Firmwide Policy on Gifts, Travel and Entertainment for more details.
Put it into Practice
That's correct.
The red flags for this situation include 1) Joe did not seek pre-approval prior to entertaining a Restricted Recipient and 2) the timing of the high-cost entertainment event may not have been appropriate. Entertaining a Restricted Recipient client in and of itself is not a red flag, but a high-cost entertainment coinciding with the timing of the entertainment may be.
Furthermore, entertainment to a Restricted Recipient may be limited to a lower entertainment amount to comply with the Restricted Recipient organization’s internal rules and local laws. Business hospitality must always be reasonable and customary, not lavish, extravagant or too frequent. It must have an underlying business purpose and provide an opportunity for business interaction with the client, not create the perception of a quid pro quo.
The firm also has a regulatory obligation to maintain accurate and complete records. Everyone involved in maintaining records or information reporting must not knowingly misrepresent, alter or omit facts. Failure to comply with the firm’s policy and exercise good judgment in the provision of gifts, travel, and entertainment can have serious consequences for the firm and the employee, including but not limited to violation of applicable anti-bribery laws and regulations. Individuals who violate this policy may also be subject to discipline, including dismissal.
That's incorrect.
The red flags for this situation include 1) Joe did not seek pre-approval prior to entertaining a Restricted Recipient and 2) the timing of the high-cost entertainment event may not have been appropriate. Entertaining a Restricted Recipient client in and of itself is not a red flag, but a high-cost entertainment coinciding with the timing of the entertainment may be.
Furthermore, entertainment to a Restricted Recipient may be limited to a lower entertainment amount to comply with the Restricted Recipient organization’s internal rules and local laws. Business hospitality must always be reasonable and customary, not lavish, extravagant or too frequent. It must have an underlying business purpose and provide an opportunity for business interaction with the client, not create the perception of a quid pro quo.
The firm also has a regulatory obligation to maintain accurate and complete records. Everyone involved in maintaining records or information reporting must not knowingly misrepresent, alter or omit facts. Failure to comply with the firm’s policy and exercise good judgment in the provision of gifts, travel, and entertainment can have serious consequences for the firm and the employee, including but not limited to violation of applicable anti-bribery laws and regulations. Individuals who violate this policy may also be subject to discipline, including dismissal.
That's incorrect.
The red flags for this situation include 1) Joe did not seek pre-approval prior to entertaining a Restricted Recipient and 2) the timing of the high-cost entertainment event may not have been appropriate. Entertaining a Restricted Recipient client in and of itself is not a red flag, but a high-cost entertainment coinciding with the timing of the entertainment may be.
Furthermore, entertainment to a Restricted Recipient may be limited to a lower entertainment amount to comply with the Restricted Recipient organization’s internal rules and local laws. Business hospitality must always be reasonable and customary, not lavish, extravagant or too frequent. It must have an underlying business purpose and provide an opportunity for business interaction with the client, not create the perception of a quid pro quo.
The firm also has a regulatory obligation to maintain accurate and complete records. Everyone involved in maintaining records or information reporting must not knowingly misrepresent, alter or omit facts. Failure to comply with the firm’s policy and exercise good judgment in the provision of gifts, travel, and entertainment can have serious consequences for the firm and the employee, including but not limited to violation of applicable anti-bribery laws and regulations. Individuals who violate this policy may also be subject to discipline, including dismissal.
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Dig Deeper
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Bribery Risk: Political and Charitable Contributions
At the Core
Never Solicit Contributions for Improper Purposes
Never make or solicit a political or charitable contribution or engage in political or charitable activity to improperly influence or obtain or retain business or a business advantage or government action.
Be Aware of Appearances
Even contributions to bona fide charities may create the appearance of potential bribery, if linked to firm business, or a government action.
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 the Anti-Bribery Group.
The firm also requires pre-approval before our people (and in certain cases or jurisdictions, spouses and dependents) make political contributions or otherwise engage in political activity.
Time to Focus: Learn the Red Flags
Review the Firmwide Policy on Charitable Contributions for a full list of red flags.
Put it into Practice
That's correct.
A red flag for this situation was that the prospective client indicates that business will be awarded only if another table is purchased, which may indicate quid pro quo.
The fact that the prospective client has a leadership position with the non-profit or that the PMD supports the organization are not red flags. This purchase would qualify as a bona fide business-related charitable contribution.
Contributions made at the request of any party with whom the firm has or is actively soliciting a business relationship, including current or prospective clients, need to be approved by the relevant business approver and the Executive Office. Certain business-related charitable contribution requests will require additional approval from the Anti-Bribery Group in Compliance.
That's incorrect.
A red flag for this situation was that the prospective client indicates that business will be awarded only if another table is purchased, which may indicate quid pro quo.
The fact that the prospective client has a leadership position with the non-profit or that the PMD supports the organization are not red flags. This purchase would qualify as a bona fide business-related charitable contribution.
Contributions made at the request of any party with whom the firm has or is actively soliciting a business relationship, including current or prospective clients, need to be approved by the relevant business approver and the Executive Office. Certain business-related charitable contribution requests will require additional approval from the Anti-Bribery Group in Compliance.
That's incorrect.
A red flag for this situation was that the prospective client indicates that business will be awarded only if another table is purchased, which may indicate quid pro quo.
The fact that the prospective client has a leadership position with the non-profit or that the PMD supports the organization are not red flags. This purchase would qualify as a bona fide business-related charitable contribution.
Contributions made at the request of any party with whom the firm has or is actively soliciting a business relationship, including current or prospective clients, need to be approved by the relevant business approver and the Executive Office. Certain business-related charitable contribution requests will require additional approval from the Anti-Bribery Group in Compliance.
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Dig Deeper
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The Sum of It
Before you go…
Remember: You are the firm’s best defense against bribery and corruption!
You receive a cold call from an independent wealth advisor to discuss a potential opportunity to onboard ultra-high net worth individuals from Jordan. The potential ultra-high net worth clients are known to be linked to the Jordanian royal family. The advisor has no public profile or track record but claims to have established relationships with the potential clients. The advisor says that the potential clients need to be onboarded quickly and they expect a significant finder’s fee for the introduction. You escalate to the Anti-Bribery Group for due diligence review.
Which of the following are red flags in this situation? Note: Read the options carefully. There may be more than one correct answer.
That's correct.
Red flags for this situation are that the ‘advisor’ has no public profile, their qualifications are questionable and they expressed urgency in moving the deal forward with clients who may be politically exposed. The correct course of action was to escalate the situation to the Anti-Bribery Group as a potential intermediary.
Important: This was a real intermediary case which resulted in a decline. For more red flags, please refer to the Firmwide Policy on Intermediaries/Finders.
Partially correct.
Red flags for this situation are that the ‘advisor’ has no public profile, their qualifications are questionable and they expressed urgency in moving the deal forward with clients who may be politically exposed. The correct course of action was to escalate the situation to the Anti-Bribery Group as a potential intermediary.
Important: This was a real intermediary case which resulted in a decline. For more red flags, please refer to the Firmwide Policy on Intermediaries/Finders.
That's incorrect.
Red flags for this situation are that the ‘advisor’ has no public profile, their qualifications are questionable and they expressed urgency in moving the deal forward with clients who may be politically exposed. The correct course of action was to escalate the situation to the Anti-Bribery Group as a potential intermediary.
Important: This was a real intermediary case which resulted in a decline. For more red flags, please refer to the Firmwide Policy on Intermediaries/Finders.
A deal team in AWM engaged a consultant to help source buyers of illiquid equity positions in China. The consultant identifies potential buyers and sends the names to Goldman Sachs. The deal team is under pressure to sell the positions quickly and decides that it would take too long to onboard the consultant. They agree with the consultant that the buyer of the position will compensate them, and Goldman Sachs will provide a discount on the positions to offset the payment.
What should the team have done differently? Remember to read the options carefully. There may be more than one correct answer.
That's correct.
The consultant in this case is a direct intermediary as it will be identifying potential buyers (business-related opportunities). You must escalate both direct and indirect intermediaries to the Anti-Bribery Group for pre-approval. Anti-Bribery Group’s approval is required for all intermediary engagements, prior to executing contracts and making payments. You should contact the Anti-Bribery Group if an approved intermediary is being engaged for a new opportunity. For more information refer to the Firmwide Policy on Intermediaries/Finders.
Partially correct.
The consultant in this case is a direct intermediary as it will be identifying potential buyers (business-related opportunities). You must escalate both direct and indirect intermediaries to the Anti-Bribery Group for pre-approval. Anti-Bribery Group’s approval is required for all intermediary engagements, prior to executing contracts and making payments. You should contact the Anti-Bribery Group if an approved intermediary is being engaged for a new opportunity. For more information refer to the Firmwide Policy on Intermediaries/Finders.
That's incorrect.
The consultant in this case is a direct intermediary as it will be identifying potential buyers (business-related opportunities). You must escalate both direct and indirect intermediaries to the Anti-Bribery Group for pre-approval. Anti-Bribery Group’s approval is required for all intermediary engagements, prior to executing contracts and making payments. You should contact the Anti-Bribery Group if an approved intermediary is being engaged for a new opportunity. For more information refer to the Firmwide Policy on Intermediaries/Finders.
The firm agreed to hire DEF Consultants, a vendor located in Poland, to oversee construction of an office space. The vendor will be responsible for obtaining approvals and permits from the local ministry for construction of the office space. The vendor representative tells the Goldman Sachs Vendor Relationship Owner that he is a long-time friend of the head of the government department that approves these permits and frequently requests additional fees for expediting approvals.
Should you escalate this vendor to Compliance? Remember to read the options carefully.
That's correct.
When selecting a vendor, statements ensuring favorable and expedited results can be a potential bribery red flag. Improper intent could be inferred by such statements, including that the third party may pay bribes or facilitation payments to those in a position of influence to get favorable advantages. Any amount of money used in this capacity is prohibited. The firm could ultimately be held liable for a third party’s corrupt actions. For more information refer to the Firmwide Policy Regarding Anti-Bribery.
Partially correct.
When selecting a vendor, statements ensuring favorable and expedited results can be a potential bribery red flag. Improper intent could be inferred by such statements, including that the third party may pay bribes or facilitation payments to those in a position of influence to get favorable advantages. Any amount of money used in this capacity is prohibited. The firm could ultimately be held liable for a third party’s corrupt actions. For more information refer to the Firmwide Policy Regarding Anti-Bribery.
That's incorrect.
When selecting a vendor, statements ensuring favorable and expedited results can be a potential bribery red flag. Improper intent could be inferred by such statements, including that the third party may pay bribes or facilitation payments to those in a position of influence to get favorable advantages. Any amount of money used in this capacity is prohibited. The firm could ultimately be held liable for a third party’s corrupt actions. For more information refer to the Firmwide Policy Regarding Anti-Bribery.
Martina, an analyst in GIR, came across a media article in a foreign-language publication about a vendor that she manages being investigated by the authorities for suspected bribery allegations.
What should Martina do? Remember to read the options carefully.
That's correct.
Negative media about a vendor under investigation by authorities for suspected bribery is a serious matter and should be escalated to your manager and the Anti-Bribery Group.
Partially correct.
Negative media about a vendor under investigation by authorities for suspected bribery is a serious matter and should be escalated to your manager and the Anti-Bribery Group.
That's incorrect.
Negative media about a vendor under investigation by authorities for suspected bribery is a serious matter and should be escalated to your manager and the Anti-Bribery Group.
Arun, a vice president in AWM, is responsible for summer internship recruitment. An MD on his team refers a candidate after the application deadline, stating that the candidate is the son of a senior executive at an investment firm. AWM is pitching co-investment opportunities to the executive, and hiring the candidate would “put Goldman Sachs in a good position” according to an e-mail from the MD. The candidate does not appear to be sufficiently qualified for the role, but without notifying HCM, Arun arranges for members of his team to interview the candidate. Arun tells the interviewers that the candidate is connected to a client and was referred by an MD.
Which of the following are red flags in this situation? Remember to read the options carefully. There may be more than one correct answer.
That's correct.
The MD should not have suggested that hiring the candidate would “put Goldman Sachs in a good position” knowing that there are pending business discussions. Also, Arun should have informed HCM that his team wanted to interview a candidate who is connected to a client and therefore a relationship candidate, regardless of the fact that their MD requested the interviews.
Under the Firmwide Policy on Relationship Candidates, you must notify HCM when a candidate is referred by or connected to a client, potential client, or public (government) official. If such a relationship candidate is selected to receive an offer, HCM will escalate the candidate to the Anti-Bribery Group for review and approval before the candidate receives a verbal or written offer. The Anti-Bribery Group will review the candidate and the hiring process to ensure that the hiring is based on merit and that the candidate is qualified and receives positive feedback.
Partially correct.
The MD should not have suggested that hiring the candidate would “put Goldman Sachs in a good position” knowing that there are pending business discussions. Also, Arun should have informed HCM that his team wanted to interview a candidate who is connected to a client and therefore a relationship candidate, regardless of the fact that their MD requested the interviews.
Under the Firmwide Policy on Relationship Candidates, you must notify HCM when a candidate is referred by or connected to a client, potential client, or public (government) official. If such a relationship candidate is selected to receive an offer, HCM will escalate the candidate to the Anti-Bribery Group for review and approval before the candidate receives a verbal or written offer. The Anti-Bribery Group will review the candidate and the hiring process to ensure that the hiring is based on merit and that the candidate is qualified and receives positive feedback.
That's incorrect.
The MD should not have suggested that hiring the candidate would “put Goldman Sachs in a good position” knowing that there are pending business discussions. Also, Arun should have informed HCM that his team wanted to interview a candidate who is connected to a client and therefore a relationship candidate, regardless of the fact that their MD requested the interviews.
Under the Firmwide Policy on Relationship Candidates, you must notify HCM when a candidate is referred by or connected to a client, potential client, or public (government) official. If such a relationship candidate is selected to receive an offer, HCM will escalate the candidate to the Anti-Bribery Group for review and approval before the candidate receives a verbal or written offer. The Anti-Bribery Group will review the candidate and the hiring process to ensure that the hiring is based on merit and that the candidate is qualified and receives positive feedback.
Rohit, a vice president in GBM Private, is having lunch with a former colleague who leads a corporation that is a prospective client. The colleague mentions that her daughter is in college and is interested in working in finance. Rohit knows the daughter and thinks that she would be a great fit for Goldman Sachs. The next day, the former colleague sends Rohit an e-mail with his daughter’s resume attached.
What should Rohit do? Remember to read the options carefully.
That's correct.
The Firmwide Policy on Relationship Candidates makes it clear that the offer or promise of a benefit to a prospective client in order to retain business or gain an improper business advantage is prohibited.
Rohit may refer the daughter to the firm as a candidate but must disclose the prospective client relationship to HCM to ensure that the Anti-Bribery Group reviews the candidate. Rohit should not provide any offer or assurance of employment to the client or attempt to influence the interview or hiring process in any way.
If necessary, Rohit should tell the former colleague that, due to internal policy, he cannot influence or be involved in the hiring process, but will forward the daughter’s resume to the firm’s recruiting team who will advise on next steps.
Partially correct.
The Firmwide Policy on Relationship Candidates makes it clear that the offer or promise of a benefit to a prospective client in order to retain business or gain an improper business advantage is prohibited.
Rohit may refer the daughter to the firm as a candidate but must disclose the prospective client relationship to HCM to ensure that the Anti-Bribery Group reviews the candidate. Rohit should not provide any offer or assurance of employment to the client or attempt to influence the interview or hiring process in any way.
If necessary, Rohit should tell the former colleague that, due to internal policy, he cannot influence or be involved in the hiring process, but will forward the daughter’s resume to the firm’s recruiting team who will advise on next steps.
That's incorrect.
The Firmwide Policy on Relationship Candidates makes it clear that the offer or promise of a benefit to a prospective client in order to retain business or gain an improper business advantage is prohibited.
Rohit may refer the daughter to the firm as a candidate but must disclose the prospective client relationship to HCM to ensure that the Anti-Bribery Group reviews the candidate. Rohit should not provide any offer or assurance of employment to the client or attempt to influence the interview or hiring process in any way.
If necessary, Rohit should tell the former colleague that, due to internal policy, he cannot influence or be involved in the hiring process, but will forward the daughter’s resume to the firm’s recruiting team who will advise on next steps.
Your college friend is now a senior executive at a client’s business, which is a state-owned entity in Singapore. You would like to invite your friend to a sporting event and a meal next weekend to discuss potential business collaborations.
What should you do?
That's correct.
This will not be a personal lunch, as you will be meeting with your friend who is a client to discuss business. The Firmwide Policy on Gifts, Travel and Entertainment indicates that all gifts, travel to and entertainment of Restricted Recipients (which include employees of state-owned enterprises), even the most nominal, must be pre-approved. Offering and receiving cash and cash equivalents, including a gift voucher, are generally prohibited.
Partially correct.
This will not be a personal lunch, as you will be meeting with your friend who is a client to discuss business. The Firmwide Policy on Gifts, Travel and Entertainment indicates that all gifts, travel to and entertainment of Restricted Recipients (which include employees of state-owned enterprises), even the most nominal, must be pre-approved. Offering and receiving cash and cash equivalents, including a gift voucher, are generally prohibited.
That's incorrect.
This will not be a personal lunch, as you will be meeting with your friend who is a client to discuss business. The Firmwide Policy on Gifts, Travel and Entertainment indicates that all gifts, travel to and entertainment of Restricted Recipients (which include employees of state-owned enterprises), even the most nominal, must be pre-approved. Offering and receiving cash and cash equivalents, including a gift voucher, are generally prohibited.
Marjory from PWM purchased tickets to a music concert for a group of clients, costing US$510 per person. Since Marjory was authorized to spend only up to the firm limit of US$251 per person, she used her personal funds to pay for the excess amount and submitted an expense claim for US$251 per person only.
How should Marjory have handled this? Remember to read the options carefully. There may be more than one correct answer.
That's correct.
You must accurately report and record all attendee/recipient names, the nature, location and total cost of the gift, travel or entertainment in Concur, as opposed to 'topping-off' the excess amount with personal funds. Note that providing inaccurate information regarding gifts, travel and entertainment can subject the firm to penalties for failing to maintain accurate books and records and is in breach of the Firmwide Policy on Gifts, Travel and Entertainment. You should use good judgment and ensure that the gift, travel or entertainment is appropriate and allows for sufficient business interaction.
Partially correct.
You must accurately report and record all attendee/recipient names, the nature, location and total cost of the gift, travel or entertainment in Concur, as opposed to 'topping-off' the excess amount with personal funds. Note that providing inaccurate information regarding gifts, travel and entertainment can subject the firm to penalties for failing to maintain accurate books and records and is in breach of the Firmwide Policy on Gifts, Travel and Entertainment. You should use good judgment and ensure that the gift, travel or entertainment is appropriate and allows for sufficient business interaction.
That's incorrect.
You must accurately report and record all attendee/recipient names, the nature, location and total cost of the gift, travel or entertainment in Concur, as opposed to 'topping-off' the excess amount with personal funds. Note that providing inaccurate information regarding gifts, travel and entertainment can subject the firm to penalties for failing to maintain accurate books and records and is in breach of the Firmwide Policy on Gifts, Travel and Entertainment. You should use good judgment and ensure that the gift, travel or entertainment is appropriate and allows for sufficient business interaction.
Claudia is an MD in Brazil. She is handling a request from the CEO of a prospective client to contribute US$25,000 to a non-profit organization. The prospective client’s CEO is currently running for political office and sits on the board of directors of the non-profit. A similar request was approved last year.
What should Claudia do?
That's correct.
This charitable contribution presents potential bribery risk because it may appear to be an attempt by the firm to improperly influence the prospective client’s CEO to award business to the firm. All business-related charitable contributions must be reviewed and approved by the Executive Office. The prospective client’s CEO running for political office also makes this a high-risk charitable contribution.
The Executive Office liaises with the relevant groups in Legal and Compliance to review such client-requested contributions in appropriate circumstances. For more information refer to the Firmwide Policy on Charitable Contributions and the Firmwide Policy on Global Political Contributions and Activities.
Partially correct.
This charitable contribution presents potential bribery risk because it may appear to be an attempt by the firm to improperly influence the prospective client’s CEO to award business to the firm. All business-related charitable contributions must be reviewed and approved by the Executive Office. The prospective client’s CEO running for political office also makes this a high-risk charitable contribution.
The Executive Office liaises with the relevant groups in Legal and Compliance to review such client-requested contributions in appropriate circumstances. For more information refer to the Firmwide Policy on Charitable Contributions and the Firmwide Policy on Global Political Contributions and Activities.
That's incorrect.
This charitable contribution presents potential bribery risk because it may appear to be an attempt by the firm to improperly influence the prospective client’s CEO to award business to the firm. All business-related charitable contributions must be reviewed and approved by the Executive Office. The prospective client’s CEO running for political office also makes this a high-risk charitable contribution.
The Executive Office liaises with the relevant groups in Legal and Compliance to review such client-requested contributions in appropriate circumstances. For more information refer to the Firmwide Policy on Charitable Contributions and the Firmwide Policy on Global Political Contributions and Activities.
James, a vice president in the Executive Office, meets with a City Council member of a city in which the firm is considering opening a new branch of its business. After the meeting, James returns to his office and finds an e-mail from the City Council member stating: “James, it was great to meet you. The city is excited to hear about your plans for expansion. As you know it can be a challenge to get all the necessary permits in a smooth and speedy manner. As I am sure you can appreciate, a little corporate citizenship can go a long way. Let’s discuss at our next meeting.”
What action should James take?
That's correct.
The City Council member’s comment could be construed as soliciting a quid pro quo – a favor or advantage granted or expected in return for something. In this situation it is necessary to engage Compliance to carefully assess the City Council member’s suggestion and to gather additional information to clarify the comment before proceeding with any additional meetings. For more information refer to the Firmwide Policy Regarding Anti-Bribery.
Partially correct.
The City Council member’s comment could be construed as soliciting a quid pro quo – a favor or advantage granted or expected in return for something. In this situation it is necessary to engage Compliance to carefully assess the City Council member’s suggestion and to gather additional information to clarify the comment before proceeding with any additional meetings. For more information refer to the Firmwide Policy Regarding Anti-Bribery.
That's incorrect.
The City Council member’s comment could be construed as soliciting a quid pro quo – a favor or advantage granted or expected in return for something. In this situation it is necessary to engage Compliance to carefully assess the City Council member’s suggestion and to gather additional information to clarify the comment before proceeding with any additional meetings. For more information refer to the Firmwide Policy Regarding Anti-Bribery.
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