Remember the Basics
Giving, or promising or receiving something of value because you want to influence the outcome of the decision is the definition of this crime.
What is a bribery?
Considered the most important asset/ resource of WSCL and must be treated confidentially.
What is information?
Of modest value, provided openly, promotional items, consistent with customary practice are all characteristics of these.
What are characteristics of gifts considered acceptable.
This is the Policy that guides staff when reporting violations of the Anti Bribery/ Corruption Policies in WSCL.
What is the Whistleblowing Policy?
Debarment, legal fines and termination of contracts are the possible consequences of this
What is engaging in bribery and corruption?
This is the minimum # of persons that are required in a bribe.
What is at least 2 persons?
It is important to think about this before disclosing information to fellow staff members.
What is whether they have a business "need-to-know" or whether you received approval.
Elected officials, candidates for public office, political parties, and officers, employees, & representatives political parties are examples of this, that can result in a COI.
What are Public Officials
Even if a gift was ________, it must still be reported to the Compliance Manager.
What is rejected?
These are 2 of your personal obligations under the WSCL ABAC Compliance Policies.
What are: complying with requirements, reporting violations and seeking guidance when unsure
Cash, lavish gifts/entertainment/meals, paid vacation, charitable and political contributions, free products, and information are all examples of this.
What are things that can be exchanged in a bribe.
WSCL must ensure that this is prepared in a legible, true, accurate and complete manner and any falsification and destruction of it is illegal.
What are the books and records of WSCL?
Ensuring you act honestly and in the best interest of WSCL at all times, is your staff obligation in this area.
What is Conflicts of Interest.
These are the persons to whom a report can be made under the Whistleblowing Policy.
Who are Managers or Coordinators, Compliance or the Executive Management Team?
Besides Policies, these are the other 3 elements of the ABAC Framework in WSCL.
What are appointing a Compliance Manager, annual training, and continuous checks for compliance?
This is the purpose or motive of a bribe.
What is to get something you are not automatically entitled to?
Any misuse of WSCL's _________ can lead to disciplinary action, up to and including termination.
What is resources or assets?
Public Officials usually request payments to _____ in order to hide the true nature of a bribe and make it appear legal.
What are charities?
These are 2 examples of what must be reported under the WSCL Whistleblowing Policy.
Illegal/ unethical conduct
Any violation of Policy
Fraud
This is a learned assumption, belief, or attitude that if not properly addressed, can negatively impact a company’s workplace culture and team dynamics.
What is unconscious bias?
The type of bribe that is paid to an official in order to speed up the performance of a routine government action.
What is a facilitation or grease payment?
If decisions are made based in WSCL on race, colour, religion, age, gender, nationality, or any other basis, we have broken the law because we created an environment where this occurs.
What is discrimination?
Any relationships with these 3 categories are treated as automatic Conflicts of Interest.
What are relationships with suppliers, customers, and competitors.
Giving poor performance reviews, exclusion from team meetings, taking away opportunities for promotion or training, firing....are all examples of this which is prohibited in our Whistleblowing Policy.
What is Retaliation?
"I'm doing it for a good cause...or others are doing far worse...or it's not a big deal"...are all excuses to rationalize what topic that featured in the Compliance Newsletter in 2024.
What is Ethical Fading?