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When does gift giving or corporate hospitality become bribery? Presenters from: Institute of Business Ethics, Norton Rose LLP and EADS March 10 th 2011.

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Presentation on theme: "When does gift giving or corporate hospitality become bribery? Presenters from: Institute of Business Ethics, Norton Rose LLP and EADS March 10 th 2011."— Presentation transcript:

1 When does gift giving or corporate hospitality become bribery? Presenters from: Institute of Business Ethics, Norton Rose LLP and EADS March 10 th 2011

2 Welcome and introductions Paul Rew European Counsel Pedro Montoya Global Chief Compliance Officer EADS Philippa Foster-Back Director, Institute of Business Ethics Sam Eastwood Partner

3 Introduction The UK Bribery Act – Gifts & Hospitality The MOJ guidance states hospitality should be 'reasonable and proportionate‘ which to some organisations is far too vague and highly subjective. However with the increased consequences for breaching the Act, it is crucial organisations set clear policies for gifts and hospitality, leaving no doubt in the minds of their employees how they should conduct business. This webcast will discuss the following topics: The legal background Gift giving & receiving – The challenges Hospitality and Entertainment - Where do organisations draw the line? what is excessive and what’s reasonable? Practical steps companies can take to ensure they don’t fall foul of the UK Bribery Act

4 Gifts & hospitality - The legal background The UK Bribery Act – the current state of play The MOJ guidance –How it relates to gifts & hospitality –Implications for businesses How the FCPA currently addresses gifts & hospitality

5 Gift giving & receiving – the challenges Opposing cultural values create problems Striking the balance between managing risk with maintaining business relationships When is a gift not a gift? – defining what is acceptable both legally and ethically Setting of financial limits – help or hindrance?

6 Safe guarding your organisation Adequate procedures – gifts and hospitality –Policies & procedures –Risk analysis –Due diligence –Top level commitment –Effective communication of your policy –Monitoring & reporting

7 Practical steps to deal with gifts & hospitality EADS - How we address gifts & hospitality –Monetary thresholds set & adapted by country –Importance of The ‘nature of the gift’ The timing of the gift The recipient of the gift – decision maker –Decision making principles -3 point test Reasonable Socially acceptable Intention to influence

8 Practical steps to deal with gifts & hospitality Making your corporate hospitality policy effective –Training - decision making principles –Recording of gifts & entertainment –Good clear policies

9 Polling question results Q1: Does your organisation set monetary thresholds for gifts and hospitality?

10 Polling question results Q2: Does your organisation have a central gifts register in place?

11 Polling question results Q3:In light of the Bribery Act, which of the following anti-bribery suggestions are you likely to implement in the next 3-6months?

12 Polling question results Q3: Does your organisation set monetary thresholds for gifts and hospitality?

13 Polling question results Q4: SAI Global plan to host more anti-bribery focused webcasts, which of the following topics would you like to hear us discuss?

14 Questions & Answers Session A follow up document will be produced in conjunction with our panel which will aim to incorporate the answers to the questions posed during this webcast For more information Write to us: info.emea@saiglobal.cominfo.emea@saiglobal.com Visit: www.saiglobal.com/compliancewww.saiglobal.com/compliance


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