CCEP Anti-Corruption Practices 4

Question 1

A government relations employee proposes hiring the son of a senior customs official as an intern. What anti-corruption risk does this raise?

Accepted Answer

A potential 'thing of value' to a foreign official implicating anti-bribery laws

Answer

Hiring relatives of government officials can constitute providing a 'thing of value' to a foreign official under the FCPA if done to obtain or retain business advantage.

Question 2

What is the significance of the 'adequate procedures' defense under Section 7 of the UK Bribery Act?

Accepted Answer

It provides a complete defense if the company can demonstrate proportionate anti-bribery procedures were in place

Answer

The 'adequate procedures' defense under the UK Bribery Act provides a complete defense to the corporate failure-to-prevent offense if the company demonstrates proportionate, risk-based procedures were in place.

Question 3

Which of the following is the best indicator that an anti-corruption compliance program has 'tone at the top'?

Accepted Answer

Senior leaders actively communicate the importance of compliance and visibly model ethical behavior

Answer

Genuine tone at the top requires active, consistent behavioral modeling by senior leaders, not merely formal certifications or periodic communications.

Question 4

A company operating in a country with an anti-bribery law that conflicts with local business customs should:

Accepted Answer

Apply the stricter of the home country or host country anti-bribery standards

Answer

When operating across jurisdictions, companies should apply the stricter applicable standard to avoid liability under any of the potentially applicable anti-bribery laws.

Question 5

What is a 'red flag' in anti-corruption due diligence on third parties?

Accepted Answer

A third party that requests payment to undisclosed accounts or in cash

Answer

Requests for payment to undisclosed accounts or in cash are classic corruption red flags suggesting funds may be used for illicit purposes.

(CCEP) Certified Compliance and Ethics Professional Practice Test

(CCEP) Certified Compliance and Ethics Professional Practice Test

CCEP Anti-Corruption Practices 4