Festival Policies
What is Festival's threshold for gifting?
$100
What does FCPA stand for?
Foreign Corrupt Practices Act
What are the penalties under the UK Bribery Act ?
up to 10 years in prison and unlimited fines
Festival employees hand out merchandise with our logo at a cruise conference.
Not a gift.
What should you do if you are unsure if something violates our policy?
Ask your supervisor or Legal/Complicane
Can you go to prison for violating the FCPA?
Yes.
What are two of the best practices/six principles fo the UK bribery act?
•Proportionality
•Top-Level Commitment
•Risk Assessment
•Due Diligence
•Communication and
•Monitoring and Review.
A festival employee pays the bar tab for one round of drinks for other attendees at the cruise conference?
Not a gift.
What happens when you will be working in a country that follows another anti-bribery act (not FCPA or UK bribery act)?
You will receive a short training quiz before your trip departs
What are the financial penalties for violations?
Up to $2,000,000 in criminal penalties. Up to $10,000 in civil penalties
Does the UK Bribery Act allow facilitation payments?
No!
A festival employee gives a foreign border official tickets to the Taylor Swift concert in order to get their ship a better docking time.
It's a gift!
What is one question to ask when determine if a gift would violate our policies?
What impact will the gift have on the recipient?
Who governs the FCPA?
•DOJ
•SEC
Who governs the UK bribery act?
Serious Fraud Office and National Crime Agency or relevant police force
a festival employee gives a foreign official an extravagant birthday present.
Why does Festival have this policy in place?
It's the right thing to do!
Does the FCPA only apply to US citizens?
No!
what companies are subject to the UK bribery act?
The Bribery Act applies to both UK companies and foreign companies with operations in the UK
A festival employee a foreign official a cow (that they purchased for less than $100) in a country where they are highly valued.
It's probably a gift!