Anti-Corruption Practices Flashcards
7 cards from real CCEP practice questions. Tap to flip, then mark Knew It or Still Learning — missed cards come back until you master them.
Read the first 7 Anti-Corruption Practices flashcards as text
Under the Foreign Corrupt Practices Act (FCPA), which of the following is considered a 'foreign official'?
Answer: An employee of a foreign government-owned enterprise
The FCPA broadly defines 'foreign official' to include employees of state-owned or state-controlled enterprises, not just government employees.
A company discovers that a third-party distributor paid bribes to win contracts on the company's behalf. Under the FCPA, which legal theory most likely exposes the company to liability?
Answer: The 'knew or should have known' standard for third-party acts
The FCPA imposes liability when a company knew or consciously disregarded red flags that a third party was paying bribes on its behalf.
Which element distinguishes a legitimate facilitation payment from a bribe under the FCPA?
Answer: The payment is made to expedite a routine non-discretionary government action
The narrow FCPA facilitation payment exception applies only to payments that expedite routine, non-discretionary ministerial acts by government officials.
What does the UK Bribery Act 2010 require that the FCPA does not?
Answer: A corporate offense for failing to prevent bribery
The UK Bribery Act's Section 7 creates a strict liability corporate offense for failure to prevent bribery, with an 'adequate procedures' defense unavailable under the FCPA.
A compliance officer reviews a due diligence report showing a potential joint venture partner has unresolved bribery allegations. What is the most appropriate next step?
Answer: Require enhanced due diligence and contractual anti-bribery representations before proceeding
Unresolved bribery allegations are a significant red flag requiring enhanced due diligence and contractual protections before any business relationship proceeds.
Which of the following best describes 'books and records' provisions under the FCPA?
Answer: Requirements for issuers to keep accurate books reflecting transactions and to maintain adequate internal controls
The FCPA's accounting provisions require issuers to maintain books and records that accurately and fairly reflect transactions and to devise and maintain adequate internal accounting controls.
What is the primary purpose of an anti-corruption 'gifts and hospitality' policy threshold?
Answer: To define a bright-line value above which approval or prohibition is triggered
Threshold limits in gifts and hospitality policies create clear, administrable rules that flag potentially problematic transfers of value for additional scrutiny or prohibition.