1 Gifts & Bribery: Kevin Weisner Finance Concentration Graduating May 2012 Ginny Jurgensen Marketing Concentration Graduating May 2012 Samantha Cranford Marketing Concentration Graduating May 2012 Lisa Kowalczyk Marketing Concentration Graduating May 2012

2 "UK firm Octel bribed Iraqis to keep buying toxic fuel additive.” In 2010, Octel, a firm in the UK, bribed Iraqis to purchase their toxic fuels known as TEL, tetra ethyl lead. Paul Jennings, chief executive for Octel, was behind the bribe operations. Jennings stepped down from his position and became CEO of Innospec. TEL petrol contains lead that can damage to children's brains at a young age. The article stated that Octel admitted to an undisclosed amount over a million dollar.

3 Google’s View on Gifts, Entertainment and Payments: Gifts, Entertainment and Payments Accepting gifts or entertainment from a Google customer, supplier, partner or competitor can easily create the appearance of a conflict of interest, especially if the value of the gift or entertainment is significant. As a result, Google policy prohibits Googlers accepting significant gifts, entertainment or any other business courtesy (including discounts or benefits that are not made available to all Googlers) from any of our customers, suppliers, partners or competitors. Acceptance of inexpensive "token" non-cash gifts, infrequent and moderate business meals and entertainment and infrequent invitations to local sporting events and celebratory meals can be appropriate aspects of many Google business relationships, provided that they aren't excessive and don't create the appearance of impropriety. However, tickets to something like the Olympics, Super Bowl or World Cup, especially if travel and lodging are included, are a significant gift which, if accepted, could create at least the appearance of a conflict of interest. Don't accept significant gifts without getting the approval of your manager and Ethics & Compliance. Gifts from customers, suppliers, partners or competitors of cash or cash equivalents (e.g., gift certificates or prepaid gift cards) should never be accepted. Gifts, entertainment, and payments are direct forms of bribery. This excerpt from Google’s Code of Conduct shows their view on bribery within their company and employees. Google’s view on bribery embed ethical principles such as Universal Rules, Contributing Liberty, and Government Requirements. “ “

4 Bribery: Guidelines to ethical behavior Google’s Code of ethics in the previous slide describes under their anti-bribery laws that employees are “prohibited to use bribery in virtually every kind of commercial setting.” The rule is quite simple: do not bribe anyone, anytime, for any reason. Also, when gifts or paying for entertainment do occur and are completely necessary they should be documented and given to the Ethics and Compliance committee so that there is no confusion. If there is ever any question as to whether or not a behavior is acceptable contact the Ethics and Compliance committee. When dealing with government officials always comply with: The U.S. Foreign Corrupt Practices Act and the OECD Convention Against Corruption of Foreign Government Officials. This policy regarding government officials includes travel, lodging expenses, political contributions, job offers, and traditional gifts. Always comply with anti-bribery laws when doing business in other countries. Basically, if you are in their country continue to follow U.S. anti-bribery laws. Lastly, if an employee is suspected of bribery they will be sent before the Ethics and Compliance committee. This committee will decide whether they will be suspended or terminated.

5 Advantages to the Prohibition of Bribery at Google: Aids in economic development by decreasing the cost of business. Develops competition between other companies and employees. Organizes the distribution channel by prohibiting bribery between suppliers/customers. Restores incentives for competition based on price and quality. Strengthens market stability by keeping competition and distribution channels functioning correctly and efficiently.

6 Disadvantages of this ethics governance excerpt for a business to build reputational capital with its critical stakeholders in this situation: Does not specify what is an unacceptable dollar amount for giving or receiving gift, just says keep the value moderate. “We want to avoid the possibility that the gift, entertainment or other business courtesy could be perceived as a bribe, so it's always best to provide such business courtesies infrequently and, when we do, to keep their value moderate.” Does not define the exceptions for giving gifts to government officials. “The Honest Leadership and Open Government Act ("HLOGA") prohibits giving any gifts, including travel and other courtesies, to Members, Officers and employees of the U.S. Senate and House of Representatives unless they fit within one of a number of specific exceptions.” Specific examples are not given in the anti-bribery laws section of the code of conduct, an example might help employees better understand the companies stance on bribery.

7 Recommendations to improve ethics management in order to reduce or eliminate disadvantages: Include the set dollar amount that would be unacceptable for the following categories gifts, entertainment, lodging, airfare, dinning, etc. Be very specific in explaining what exceptions are allowed in regards to political figures. Include: Question and Answer section “What if?” Situational examples

8 Class Discussion: Based on what we told you regarding Octel… Was Iraq/UK being ethical by buying/selling the gas even though they knew it was harmful to society?

9 Works Cited: Google Investor Relations: Code Of Conduct. Web. 17 Feb Hosmer, Larue T. Brief Summary of Ten Ethical Principles. The Academy Of Management Review. Fri. 18 Feb Leigh, D., & Mahmood, M. (2010). UK Firm Octel Bribed Iraqis to Keep Buying Toxic Fuel Additive. Retrieved Jan. 30, 2011, from Octel, United Kingdom. Web site: petrol-iraq-lead.