Anti-Corruption Practices Flashcards
7 cards from real CCEP practice questions. Tap to flip, then mark Knew It or Still Learning โ missed cards come back until you master them.
Read the first 7 Anti-Corruption Practices flashcards as text
A government relations employee proposes hiring the son of a senior customs official as an intern. What anti-corruption risk does this raise?
Answer: A potential 'thing of value' to a foreign official implicating anti-bribery laws
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.
What is the significance of the 'adequate procedures' defense under Section 7 of the UK Bribery Act?
Answer: It provides a complete defense if the company can demonstrate proportionate anti-bribery procedures were in place
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.
Which of the following is the best indicator that an anti-corruption compliance program has 'tone at the top'?
Answer: Senior leaders actively communicate the importance of compliance and visibly model ethical behavior
Genuine tone at the top requires active, consistent behavioral modeling by senior leaders, not merely formal certifications or periodic communications.
A company operating in a country with an anti-bribery law that conflicts with local business customs should:
Answer: Apply the stricter of the home country or host country anti-bribery standards
When operating across jurisdictions, companies should apply the stricter applicable standard to avoid liability under any of the potentially applicable anti-bribery laws.
What is a 'red flag' in anti-corruption due diligence on third parties?
Answer: A third party that requests payment to undisclosed accounts or in cash
Requests for payment to undisclosed accounts or in cash are classic corruption red flags suggesting funds may be used for illicit purposes.
Under the OECD Anti-Bribery Convention, signatory countries are obligated to:
Answer: Criminalize the bribery of foreign public officials in international business transactions
The OECD Anti-Bribery Convention requires signatory countries to criminalize active bribery of foreign public officials in international business, creating aligned national laws.
Which compliance control best addresses the risk of employees circumventing anti-corruption policies through personal expense reimbursements?
Answer: Implementing a pre-approval process for unusual expense categories combined with audits of reimbursements
Pre-approval for unusual expense categories combined with audit sampling of reimbursements creates both preventive and detective controls over potential abuse.