Compliance
True or False: Compliance is only about preventing issues and ensuring everyone is following laws, rules, and regulations.
False! Compliance is about preventing issues and ensuring everyone is following laws, rules, and regulations; however, it is also about the positive impact of a robust and ethical compliance program can have on a business or organization.
What are the three types of bribery?
1. Commercial (private) bribery
2. Official (public) bribery
3. Kickbacks
What are trade controls?
Trade controls are restrictions on the transfer of prohibited items from certain foreign countries, individuals, and organizations to another individual, company, government, or public body.
True or False: There will be no retaliation against employees who ask questions or report their concerns.
True!
True or False: In an investigation, the investigator does not take part in the disciplinary decision but is present to answer follow-up questions.
True!
True or False: deugro employees could be held personally liable for compliance issues?
True! Issues in compliance regulations can lead to monetary fines or criminal actions against individual employees by the government.
True or False: gifts can never be given in the form of cash; however, as long as the gift fall within the spending limits, it can be given as a visa gift card.
What is false! Both cash and cash equivalents (such prepaid cash gift cards) can never be given as a gift.
When should you seek a trade controls review?
As soon as you become aware of potential business to a restricted or forbidden country, but ALWAYS prior to the transaction commencing.
Who is the Local Ethics Officer (LEO) in your branch office?
deugro (USA), Inc. (Erie):
Christopher Slawson
deugro (USA), Inc. (HOU):
Alicia Evans
deugro (USA), Inc. (MIA):
Robert Lazcano
deugro (USA), Inc. (GREEN):
Adam Lawson
dship Carriers (Americas), Inc.:
Sven Michelsen
deugro (Canada), Inc. (TORONTO):
Dipika Malhotra
True or False: deugro employee's can use deugro funds to make political contributions to candidates who support deugro's business.
What are three of the six ways bribe money exchanges hands?
All of the following are ways bribe money exchanges hands:
1. Gifts & hospitality
2. Employment
3. Facilitation Payments
4. Third Party Intermediaries
5. Charitable Contributions
6. Kickbacks
What email address do you contact when you believe a trade controls review needs to be conducted?
tradecontrols@deugro.com
What are the three steps of the investigation and disciplinary process?
The three steps are: report, investigation, and disciplinary committee.
For business partner hospitality, what is the maximum dollar amount that does not require approval?
What are three potential penalties for non-compliance?
All of the following are the costs associated with non-compliance:
1. Fines & Damages
2. Legal & Investigation Fees
3. Reputation Damage
4. Loss of Trust
5. Termination of Contracts
6. Blacklisting by Clients or Banks
7. Exclusion from Public Tenders
8. Prosecution of Individual Employees.
Name two things that are never permitted when offering gifts, hospitality, or entertainment.
All of the following are never permitted:
•Offering or receiving cash or cash equivalents (cash gift cards)
•Excessive, lavish, or frequent Gifts or Entertainment
•Gifts provided during a Tender Process
•Business Courtesies for the immediate family members, other relatives, or significant others of Public Officials and Business Partners
•Any item that might violate the Counterpart’s policy
What three departments will review, advise, and potentially mitigate reports of potential trade control issues?
Compliance, Insurance, and treasury.
Name the five reporting channels available to deugro employees.
1. Speak Up! www.deugro-group.com/speakup
2. Legal & Compliance Team
3. Senior Leaders
4. Managers
5. Local Ethics Officer
What should you do in the following situation:
Acme, one of our agents, acting in the capacity of a client, has asked us to handle their cargo in Estonia. You come to learn that in Estonia, no other agents are willing to work with us because they do not trust Acme.
In this situation, you should inform compliance@deugro-group.com and search for alternative agents to protect deugro.
Where can deugro employees find the legal and compliance organization chart and answer any compliance related questions?
On Helix or by contacting compliance@deugro-group.com
Could the following situation be considered a bribe:
A deugro employee has been struggling to receive customs clearance from a particularly difficult government employee. The deugro employee discovers that the government employee sits on the board of a charitable organization that is seeking new donors. The deugro employee, worried that their customer may be upset with the delay, makes a donation to charitable organization with the deugro employee's own money. Shortly after making the donation, the government employee allows the cargo to clear customs.
Yes, although the deugro employee used their own funds, this could be considered a bribe. Charitable donations can pose a significant risk as they can appear to channel corrupt payment.
Name five countries on the restricted and forbidden trade control list.
What is the six step third-party onboarding procedure?
Step 1: Check whether the party is already approved (can be done on helix)
Step 2: Fill in the diligence request form and contact subconmgmt@deugro-group.com
Step 3: Send the custom questionnaire from the subcontractor management team to the agent.
Step 4: Send the completed agent questionnaire to the subcontractor management team
Step 5: The subcontractor must sign the business partner acknowledgement form and an agreement from legal.
Step 6: After approval, use best judgement when using the newly approved vendor.