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## Getting Started

“If our people fail to act with integrity, the consequences for the firm are potentially very severe. It can affect our reputation. It can affect our relationship with our clients. It can affect our relationship with our regulators. And in some cases, it can have very profound consequences either for lawsuits or other enforcement actions brought against the firm. Understanding the risks associated with bribery and corruption and ensuring that issues get escalated are important responsibilities we all share.”

– Kathryn Ruemmler, Chief Legal Officer and General Counsel

## Welcome

This video contains audio and a transcript. To listen to the audio, please use your headphones or adjust your speakers.

Select the Play button to begin.

Transcript

## Important Note

A quick note about links in this training:

- Certain important terms will be underlined and will open a popup definition. These terms are mandatory to review to advance in your training and are identified by '(Review to advance)'.
- Hyperlinks to Goldman Sachs policies are also underlined. These are not mandatory for course completion. Selecting hyperlinks will open policies in a separate Chrome web browser. Once you have reviewed, close that window to return to the training window, which will still be open but may be minimized or hidden behind your Chrome web browser. Do not relaunch the training as it will impact your course completion.

## What are bribery and corruption?

There are 3 collapsible items ahead that need to be reviewed to continue.

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

When you have completed this page the Next Page button will become available.

Bribery

### Bribery

There are 2 hotwords ahead that need to be reviewed to continue.

Bribery involves improperly offering, paying, authorizing, promising, soliciting or receiving anything of value (Review to advance) with the intent to obtain or retain business, any business advantage or to influence a government or regulatory action. Bribery can involve corrupt payments to public officials (Review to advance), employees of corporate clients or suppliers, and their relatives, friends, agents and associates, and other private parties.

Corruption

### 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

### Anti-Bribery and Anti-Corruption Laws

Applicable anti-bribery and anti-corruptions laws include:

- U.S. Foreign Corrupt Practices Act (FCPA) which prohibits the payment of bribes to foreign officials to assist in obtaining or retaining business or any improper business advantage, as well as the maintenance of accurate books and records.
- U.K. Bribery Act (UKBA) which criminalizes bribery and receipt of bribes, the bribing of foreign government representatives, and the failure by private companies to prevent corruption.

## How well do you know bribery and corruption risk?

There are five main areas of heightened bribery and corruption risk. How well do you know these five areas?
Choose from one of the options below. Be honest...

Select the option that best matches your knowledge of bribery risks and then select Submit.

Very well
Very well
Sufficiently well
Sufficiently well
Need a refresher
Need a refresher
Not very well
Not very well

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

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

1. Intermediaries/Finders
2. 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 sample 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.

## Learning Objectives

At the end of this training you will be able to:

- Recognize key concepts related to bribery and corruption
- Identify the five main areas of heightened bribery and corruption risk
- Explain the rules and requirements around each area of heightened bribery and corruption risk
- Identify red flags of potential bribery and corruption and recognize when and how to escalate

Let’s check in again at the end of this training to see how comfortable you are with the five heightened areas of bribery risk and if we have achieved our learning objectives.

## Bribery Risk: Intermediaries

Did You Know...

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

There is a hotword ahead that needs to be reviewed to continue.

Intermediaries are third parties who are engaged, with or without being compensated by the firm or other parties, in connection with potential business opportunities (Review to advance), even if those opportunities do not materialize.

## At the Core

What do you need to know about intermediaries?

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Select each button to learn more.

When you have completed this page the Next Page button will become available.

Why do intermediaries pose heightened risk?

### Why do intermediaries pose heightened risk?

Intermediaries, regardless of whether they are directly or indirectly engaged and/or compensated by the firm or other parties, pose heightened risks to the firm due to their authority to act on behalf of the firm or in association with firm business and the nature of their activities (e.g., interacting with government or other public officials on our behalf), particularly as we have limited visibility into and control over their actions.

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

### 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 Compliance (Anti-Bribery Group) for enhanced due diligence and other requirements.
- Complete the Due Diligence Form for Intermediaries and Finders.
- After the Anti-Bribery Group approves the 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.

There are 2 items ahead that need to be reviewed to continue.

Select each button to learn more.

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Direct 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

### 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.

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 or public officials
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 a Politically Exposed Person (PEP) or their immediate family members or close associates
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 (Review to advance)
Will receive unusually high fees or other compensation/benefits or appears unqualified for the services being provided
Provides an invoice that appears falsified or with inflated amounts, or duplicative or vague descriptions of services
Has no identifiable media profile

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

## Put it into Practice

Read the following situation and answer the question that follows.
A team in Asset and Wealth Management (AWM) in EMEA is looking to purchase a data center, owned by a government entity, in the United Arab Emirates (UAE). Sales of government assets in the UAE require government approval. A vice president (VP) on the AWM team learned of the opportunity through an informal discussion with a former Goldman Sachs managing director (MD), who is known to the deal team for having improper conduct history. The former Goldman Sachs MD had introduced the VP to the government official who oversees the sale of the data center.

Which of the following are red flags for bribery and corruption risk in this situation? Note: Read the options carefully. There may be more than one correct answer.

The business opportunity relates to a data center.
The business opportunity relates to a data center.
The transaction requires approval by the government in a high-risk jurisdiction.
The transaction requires approval by the government in a high-risk jurisdiction.
The third party who had facilitated the introduction to the government official, is a former Goldman Sachs MD with improper conduct history.
The third party who had facilitated the introduction to the government official, is a former Goldman Sachs MD with improper conduct history.
The business opportunity came about through an informal discussion.
The business opportunity came about through an informal discussion.

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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There is a hotword ahead that needs to be reviewed to continue.

Before we continue, please select the following link (Review to advance) to complete our Firmwide Intermediaries/Finders Survey.

The purpose of this survey is to ensure that the firm has identified all direct and indirect intermediaries (as defined above) involved in business opportunities.

You must complete this survey in order to continue the training. Note that the survey will open in a separate browser window. Once you have completed the survey, close that window to return to the training window.

## Case Study: Significant and Complex Transaction

Let’s review another situation involving intermediaries.

Select the arrow button to find out more.

### A Complex Transaction

Global Banking & Markets – Private (GBM Private) was looking to finance a commercial real-estate development in Senegal. The client was a Senegalese state-owned enterprise (SOE).

A former GBM Private PMD in EMEA, who is acquainted with the head of the SOE, recommended Goldman Sachs for the opportunity and introduced the head of the SOE to the Goldman Sachs team lead.

Given the complex nature of the transaction and the involvement of a List 4 SOE, the transaction was designated as a Significant and Complex Transaction (SCT).

### Unknowns on Client Calls

During one of the Zoom meetings, the deal team noticed that there were multiple unidentified parties joining the call.

The deal team asked the SOE and was told that these individuals were local consultants and associates of prominent government officials, who have domestic connections to market the development to future tenants.

### Due Diligence Questionnaire

As part of the SCT diligence process, the deal team was asked to complete a due diligence questionnaire, including questions about the involvement of former Goldman Sachs employees and direct or indirect intermediaries.

The team responded ‘No’ to both questions because the former Goldman Sachs PMD was not directly involved in the deal, and the ‘consultants’ were not involved in the financing itself. Goldman Sachs won the mandate.

### Enhanced Diligence

As diligence progressed, Compliance learned about the former Goldman Sachs PMD and consultants. Further research revealed that the former PMD had financial ties to the head of the SOE and the ‘consultants’ were self-employed and had no relevant business experience.

Think about it…what were the red flags in this situation?

### Our Policy Requirements

The Firmwide Policy for Significant and Complex Transactions describes the SCT governance and diligence process and calls attention to red flags of bribery and corruption, including:

- Known or reported allegations, legal proceedings or investigations relating to bribery, corruption, fraud, money laundering, government sanctions or other financial crimes.
- A third party introducing a public official or government entity in connection with a transaction.
- A third party is introduced or recommended by a public official or a Politically Exposed Person (PEP).
- Questionable qualifications of the third party to perform the envisaged services.
- A third party who does not have a defined role and will not provide any services in the transaction: (i) participates in or facilitates the firm’s business discussions with the client or public officials, (ii) will receive financial or other compensation, and/or (iii) operates in a jurisdiction outside the scope of the transaction.

All indirect intermediaries must be disclosed (i) in the SCT Memorandum and responses to the Due Diligence Questions and (ii) to the Anti-Bribery Group for further review.

## Dig Deeper

Select the relevant policies to learn more.

Firmwide Policy on Intermediaries/Finders

Firmwide Policy on Country Lists

Due Diligence Form for Intermediaries and Finders

Firmwide Policy for Significant and Complex Transactions

## Bribery Risk: Vendors and Other Third Parties

Did You Know...

the firm currently has over 9,000 unique active vendors and approximately 2,300 of our people serving as Vendor Relationship Owners (VROs)?

## 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 the Anti-Bribery Group before engaging any high-risk vendors and executing contracts with those vendors.

All VROs are responsible for onboarding their vendors to the ‘Know Your Third Party’ system prior to commencing work and should have oversight of vendor conduct 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 sub-contractors should know and follow our Vendor Code of Conduct.

Third parties, including intermediaries and vendors, as well as our people, are strictly prohibited from making or routing corrupt or improper payments. Specifically, vendors are prohibited from making or soliciting facilitation ('grease') payments (i.e., payments made to public officials to facilitate or expedite a routine government action or an administrative process).

### Role of the Anti-Bribery Group

The Anti-Bribery Group conducts due diligence on high-risk vendors.

## 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 received negative media or whistleblowing 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

## Put it into Practice

The firm is entering into a joint venture with a real estate firm, which plans to hire a vendor located in Japan to oversee the construction of office space. This vendor is known to have many local connections and will be responsible for obtaining approvals and permits from local government authorities for this construction, on behalf of the joint venture. The firm agreed on a contract for US$200,000 all inclusive. However, when the first invoice arrives, it is for US$400,000 with no explanation or supporting documentation. The firm’s joint venture partner selected the vendor based on a recommendation from a local politician, rather than a competitive standard vendor bidding process.

Which of the following are red flags for bribery and corruption risk in this situation? Remember to read the options carefully. There may be more than one correct answer.

The vendor is located in a low-risk jurisdiction.
The vendor is located in a low-risk jurisdiction.
The vendor charged an unusually high fee without explanation or documentation.
The vendor charged an unusually high fee without explanation or documentation.
The vendor was referred by a local politician (i.e., government official).
The vendor was referred by a local politician (i.e., government official).

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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## Dig Deeper

Select the relevant policies to learn more.

Vendor Management Policy

Vendor Management Standard

Vendor Code of Conduct

## Bribery Risk: Relationship Candidates

Did You Know...

the firm evaluated more than 600 relationship candidates in 2023?

There are 2 hotwords ahead that need to be reviewed to continue.

The firm welcomes and considers all qualified candidates for employment (Review to advance) and internships, regardless of their connections. However, the firm has very specific rules on hiring relationship candidates (Review to advance).

## At the Core

What do you need to know about relationship candidates?

There are 4 collapsible items ahead that need to be reviewed to continue.

Select each button to learn more.

When you have completed this page the Next Page button will become available.

Immediately Escalate

### Immediately Escalate

Relationship candidates should be flagged to HCM and immediately escalated to the Anti-Bribery Group for review and approval before an offer is extended.

No Promises

### 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

### Merit-based Process

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

Post-hire Restrictions

### Post-hire Restrictions

Once relationship candidates join the firm, post-hire restrictions or ‘ring-fencing’ may be imposed on relationship candidates 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 ring-fenced individual/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 referrer recommends the relationship candidate on the same e-mail chain that discusses a pending business transaction
An internal referrer wants to hire the relationship 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
An internal referrer contacts interviewers and alerts them to the relationship candidate’s connection to a client
An internal referrer excessively coaches the relationship candidate
The firm appears to create a position specifically for the relationship candidate

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

## Put it into Practice

A PMD in GBM Public receives a call from a prominent client whose daughter is in college. In the midst of a potential business opportunity discussion, the client mentions that he would like his daughter to have a quick tour of the floor and maybe an info session with the deal team to ‘see how it all works.’ The PMD agrees immediately given the ‘important’ client relationship, reasoning that it would be a harmless ‘work shadow.’ Several months later, the daughter applies for a summer analyst position in GBM citing previous Goldman Sachs experience. The PMD is made aware of the application and coaches her on ‘model answers’ for the interviews. The PMD also regularly checks in with HCM on the interview progress and reaches out to the interviewers, indicating the importance of the client relationship. The discussion of a potential business opportunity with the client remained ongoing at the time of the daughter’s application for the summer analyst role.

Which of the following are red flags for bribery risk in this situation? Remember to read the options carefully. There may be more than one correct answer.

The PMD agreed immediately to the client’s request for the work shadow without checking with HCM or Compliance.
The PMD agreed immediately to the client’s request for the work shadow without checking with HCM or Compliance.
The firm has a pending business opportunity with the client.
The firm has a pending business opportunity with the client.
The client requests a work shadow for his daughter.
The client requests a work shadow for his daughter.
The PMD regularly checks in with HCM on the progress and reaches out to the interviewers, indicating the importance of the client relationship.
The PMD regularly checks in with HCM on the progress and reaches out to the interviewers, indicating the importance of the client relationship.
The PMD has multiple coaching sessions with the client’s daughter on the model answers.
The PMD has multiple coaching sessions with the client’s daughter on the model answers.

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

Select the policy to learn more.

Firmwide Policy on Relationship Candidates

## Bribery Risk: Gifts, Travel and Entertainment

Think about it...

Offering gifts, travel and entertainment is often helpful in strengthening business relationships, but they must be appropriate and never lavish or excessive.

Lavish or excessive gifts, travel and entertainment may improperly influence the recipient’s business judgment or have the appearance that the firm is trying to obtain or retain business in exchange of these benefits, which violates anti-bribery and anti-corruption laws and raises bribery and corruption risk to the firm.
Conversely, you should not accept gifts, travel or entertainment that are lavish or so frequent they may raise a question of impropriety. Just as you take time and care when purchasing gifts for those close to you or booking personal travel, you should pay close attention to your business offerings, receipts and expenses.

## At the Core

There is a hotword ahead that needs to be reviewed to continue.

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

Do |  | Do not
--- | --- | ---
Submit pre-approval requests in Concur for: All gifts (prior to purchase) to clients or other third parties, including Restricted Recipients (Review to advance) All travel and entertainment of Restricted Recipients, regardless of the cost All travel and entertainment (including ticketed events) to all other clients or third parties that you know in advance or expect will exceed US$250 per person |  | 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.
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.
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.

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 prospective client to a potentially lavish event ahead of a deal pitch
‘Topping off’ or failing to report the full value of gift, travel or entertainment provided by absorbing the excess amounts from personal funds
Adding attendees to request for approval to reduce the per-person cost

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

## Put it into Practice

Joe from GBM Private has been hoping to obtain the business of a sovereign wealth fund and has been pitching ideas to its CEO. The sovereign wealth fund will make a decision in the following week on which investment bank to engage as its advisor. Joe knows that the CEO enjoys fine dining, and he manages to secure a last-minute reservation at an exclusive Michelin-starred restaurant without seeking pre-approval. The CEO was available that evening and accepted Joe’s invitation. When it was time to submit his expense report, Joe was worried that the expense would be rejected as the final bill amount came to a total of GBP2,000 for two people. Joe proceeded to include multiple Goldman Sachs attendees such that the per person amount was reduced to GBP200 per person.

Which of the following are red flags for bribery risk in this situation? Remember to read the options carefully. There may be more than one correct answer.

Joe did not seek pre-approval to entertain the client, who works for a sovereign wealth fund and would be a Restricted Recipient.
Joe did not seek pre-approval to entertain the client, who works for a sovereign wealth fund and would be a Restricted Recipient.
Joe entertains a Restricted Recipient client.
Joe entertains a Restricted Recipient client.
The client was the CEO and key decision-maker at the sovereign wealth fund, and the sovereign wealth fund was about to decide whether to award an advisory mandate to Goldman Sachs.
The client was the CEO and key decision-maker at the sovereign wealth fund, and the sovereign wealth fund was about to decide whether to award an advisory mandate to Goldman Sachs.
The dinner at the Michelin-starred restaurant may be viewed as potentially excessive and lavish.
The dinner at the Michelin-starred restaurant may be viewed as potentially excessive and lavish.
Joe entered inaccurate information in his expense report, with the intention to reduce the per-person cost of the entertainment event.
Joe entered inaccurate information in his expense report, with the intention to reduce the per-person cost of the entertainment event.

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

Select the relevant links to learn more.

Firmwide Policy on Gifts, Travel and Entertainment

Concur

Receipt of G&E Tool

Corporate Credit Card Policy

Expense Policies, Procedures and Guidelines

## Bribery Risk: Political and Charitable Contributions

Think about it...

Many of our people are passionate about their political and charitable affiliations. Unfortunately, under certain circumstances these activities can present elevated bribery and corruption risks, or at least raise appearance issues.

Keep in mind that rules with respect to political activities are complex and vary by jurisdiction with severe penalties for violations.

Similarly, charitable contributions, including to bona fide charities, must never be made if the intent or effect is to inappropriately influence the business judgement of any person, including a public official, client, potential client, or government action.

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?

There are 3 items ahead that need to be reviewed to continue.

Select each button to learn more.

When you have completed this page the Next Page button will become available.

Never Solicit Contributions for Improper Purposes

### 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

### 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

### 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

Some of the common red flags for charitable contributions include:

A public official requesting or otherwise associated with a contribution
Donation solicitation received from, or recipient charity located in a jurisdiction known to be high-risk for bribery and corruption
Communications that suggest the award or contracting of business is dependent on making a contribution
The firm has pending business with the client requesting contribution
A lack of transparency around the bank account for the charitable recipient

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

## Put it into Practice

A PMD in Wealth Management invites you to attend the annual gala for a non-profit organization which he supports. The PMD mentions that he has purchased a table for the gala at the request of a prospective client who is also in a leadership position with the non-profit. It is common for wealthy individuals to have leadership positions at non-profits and for the firm to support worthy causes. Later that day, you are copied on an e-mail where the prospective client indicates that they anticipate awarding Goldman Sachs with an upcoming transaction if the firm purchases another table at the event.

Which of the following is a red flag for bribery risk in this situation? Remember to read the options carefully.

The prospective client has a leadership position with the non-profit.
The prospective client has a leadership position with the non-profit.
The prospective client indicates that business will be awarded only if another table is purchased.
The prospective client indicates that business will be awarded only if another table is purchased.
The PMD supports the non-profit organization.
The PMD supports the non-profit organization.

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

Select the relevant policies to learn more.

Firmwide Policy on Charitable Contributions

Firmwide Policy on Global Political Contributions and Activities

## The Sum of It

How well do you know bribery risks?

Now that you have learned about the five main areas of bribery and corruption risk, let’s check back in. At the beginning of this training, we asked you to choose how well you knew these five areas. Now, let’s compare how you answered the practice questions on each bribery risk with how well you thought you knew those risks.

You selected...
You answered...
Very Well
Sufficiently well
Need a refresher
Not very well
X/5 Knowledge Check questions correctly

How did you do? Are you surprised at your result? Remember, in our business there are some areas of heightened bribery and corruption risk where the warning signs aren’t immediately obvious. You need to be vigilant. If you are unsure, always escalate any questions or concerns to the Anti-Bribery Group in Financial Crime Compliance or to your Compliance officer.

## You are our best defense

This video contains audio and a transcript. To listen to the audio, please use your headphones or adjust your speakers.

Select the Play button to begin.

Transcript

## 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 policies. It is critical that we recognize and learn from important lessons along the way.

### 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

The Anti-Bribery Group 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!

# Test Yourself

##

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.

The proposed clients are potentially politically exposed.
The proposed clients are potentially politically exposed.
The potential intermediary has no identifiable media profile.
The potential intermediary has no identifiable media profile.
The potential intermediary requests a significant finder’s fee.
The potential intermediary requests a significant finder’s fee.
The potential clients are ultra-high net worth individuals.
The potential clients are ultra-high net worth individuals.
Submit

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.

The AWM team should have obtained Anti-Bribery Group’s approval before engaging the consultant and receiving potential purchaser names.
The AWM team should have obtained Anti-Bribery Group’s approval before engaging the consultant and receiving potential purchaser names.
The AWM team should not have pursued an alternative payment structure to avoid intermediary onboarding.
The AWM team should not have pursued an alternative payment structure to avoid intermediary onboarding.
The AWM team should not have engaged a consultant to find potential buyers.
The AWM team should not have engaged a consultant to find potential buyers.
Submit

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.

No. It’s important for vendors to know high-level decision-makers in order to service the firm and facilitate the project to move forward.
No. It’s important for vendors to know high-level decision-makers in order to service the firm and facilitate the project to move forward.
Yes. The relationship between the DEF representative and the head of the government department (i.e., government official) is a potential bribery red flag, as is the comment about additional fees for expediting approvals.
Yes. The relationship between the DEF representative and the head of the government department (i.e., government official) is a potential bribery red flag, as is the comment about additional fees for expediting approvals.
Submit

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.

During their next touchpoint, ask the vendor if they are aware of these allegations against them.
During their next touchpoint, ask the vendor if they are aware of these allegations against them.
Inform her manager and escalate to the Anti-Bribery Group and business-aligned Compliance.
Inform her manager and escalate to the Anti-Bribery Group and business-aligned Compliance.
Submit

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.

The MD refers a candidate for a summer analyst position.
The MD refers a candidate for a summer analyst position.
The MD suggests that hiring the candidate could help Goldman Sachs to obtain business.
The MD suggests that hiring the candidate could help Goldman Sachs to obtain business.
Without involving HCM, Arun moves forward with the candidate when he does not appear qualified and the application was received after the deadline.
Without involving HCM, Arun moves forward with the candidate when he does not appear qualified and the application was received after the deadline.
Arun told the interviewers that the candidate is connected to a client.
Arun told the interviewers that the candidate is connected to a client.
Submit

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.

Mention that his team has an open headcount and promise that his team will hire her daughter, but emphasize that it may depend on the outcome of the deal that GBM Private is pitching to the corporation.
Mention that his team has an open headcount and promise that his team will hire her daughter, but emphasize that it may depend on the outcome of the deal that GBM Private is pitching to the corporation.
Forward the resume to a colleague in GBM Public who has several open positions and mention that hiring the candidate would help GBM Private win an important client.
Forward the resume to a colleague in GBM Public who has several open positions and mention that hiring the candidate would help GBM Private win an important client.
Disclose the relationship to HCM so that the candidate is vetted through the required relationship candidate review process before a verbal or written offer is extended.
Disclose the relationship to HCM so that the candidate is vetted through the required relationship candidate review process before a verbal or written offer is extended.
Submit

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?

Nothing, it is perfectly reasonable to buy your college friend lunch.
Nothing, it is perfectly reasonable to buy your college friend lunch.
Submit your lunch for pre-clearance. Your friend is a Restricted Recipient since the client is a state-owned entity and may need to self-pay depending on their rules.
Submit your lunch for pre-clearance. Your friend is a Restricted Recipient since the client is a state-owned entity and may need to self-pay depending on their rules.
Instead of lunch, buy your friend a gift voucher as an alternative.
Instead of lunch, buy your friend a gift voucher as an alternative.
Submit

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.

Marjory did not do anything wrong as she paid for the excess amount using personal funds.
Marjory did not do anything wrong as she paid for the excess amount using personal funds.
Marjory should have reported the full value of client entertainment and disclosed the use of personal funds.
Marjory should have reported the full value of client entertainment and disclosed the use of personal funds.
Marjory should have requested pre-approval in Concur from the Anti-Bribery Group because the cost per person exceeded US$251.
Marjory should have requested pre-approval in Concur from the Anti-Bribery Group because the cost per person exceeded US$251.
Submit

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?

Claudia can move forward and process the request since a similar one was approved last year.
Claudia can move forward and process the request since a similar one was approved last year.
Claudia should submit a request and receive approval from the Executive Office for each contribution.
Claudia should submit a request and receive approval from the Executive Office for each contribution.
Submit

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?

James should respond to the e-mail and ask the commissioner more about the corporate citizenship possibilities.
James should respond to the e-mail and ask the commissioner more about the corporate citizenship possibilities.
James should immediately report the matter to the Anti-Bribery Group or divisional Compliance.
James should immediately report the matter to the Anti-Bribery Group or divisional Compliance.
Submit

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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After taking this training, I now recognize key concepts related to bribery and corruption.

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