Anti-Bribery, Corruption, Gift, Hospitality and Entertainment Policy Quiz

Q1: Which of the following statements is not a Red Flag, or indicators of potential corrupt conduct?

A history of corruption in the country in question.

An Individual avoiding leave or insisting on controlling certain accounts or relationships personally.

Lack of transparency around tendering or procurement processes.

Hosting a customer or supplier at a luncheon seminar (AUD 90) on a relevant industry topic not during tender or pitch phase

Request by a customer or public official for donations to particular charities or sponsorship of an organisation.

Q2: An Australian company is bidding for an infrastructure project in Indonesia which requires certain planning approvals to be the successful bidder. In discussions with the deputy Planning Minister, the company is asked it if would like to sponsor a local student they have pre-selected to attend a prestigious school in Sydney. The company is told that the offer of a scholarship would be looked on favourably as a show of support for the community. Would this be classified as a bribery offence? Yes or No?

YES

Case Study: Gifts Policy Worldwide Foods Limited, an Australian food technology business, has a wholly-owned subsidiary in the UK, British Beverages Limited (BBL). BLBL is tendering for a contract to build a factory in China. Ms Wilson, the Marketing Director of BBL offers a family holiday to the Gold Coast to the Head of the State-Owned Enterprise responsible for the award of the tender. The offer is declined. The Managing Director of Worldwide Foods Limited later find out about the offer and is concerned as to whether the Australian company is exposed to any liability for corruption or bribery. Should she be concerned?

Yes

Yes - Gifts and hospitality during a tender process is not acceptable. Further, the gift is not reasonable, proportionate or justifiable. The head of a Chinese SOE would be considered a foreign Public Official and the offer of the family holiday viewed as a bribe under Australian law (for the parent company if it knew, or should have known, about the bribe and exercised control over its UK subsidiary). Under the UKBA no offer of hospitality or promotional gifts is permitted if extravagant or not connected to a legitimate business purpose.

Which of the following would likely be acceptable under NTT DATA’s Gifts and in a Hospitality Policy? Select the correct Answer(s):

Taking a key client to the AFL Grand Final in a corporate box (valued at AUD 400) without prior written approval from the CEO APAC

Hosting 10 people from a customer to a Rugby match in Japan while there on business (valued at AUD1500) without prior approval from the CEO APAC

Accepting an invitation to lunch to continue business discussions with a supplier

Paying for a Customer’s ticket to an industry seminar and cocktail event (valued at AUD 100) personally and not recording it in the NTT gift Hospitality and Entertainment Register

Inviting a visiting foreign Public Official to the Australian Open Tennis using tickets you received gratis (Value AUD 250) without prior approval from the CFO

Anti-Bribery, Corruption, Gift, Hospitality and Entertainment Policy Quiz

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