A senior executive of a large electronics company would have made donations and contributions to non-profit organizations that were supposedly for charitable purposes. Later, it was known that some people linked to the government would be the real beneficiaries of these perks.

This link between charities and the government, led to an investigation for possible violation of anti-bribery and anti-corruption regulations (FCPA). It was questioned whether the true intentions of these payments were to grant bribes to obtain undue benefits from the government, instead of a philanthropic purpose. 

Learn more about this case in this link: https://youtu.be/EuF-vFK_N1A

This case teaches us that even the smallest decisions can bring large changes within organizations, both positive and negative.

It is possible that the course of events for this electronics company would have been different if they had been diligent in the identification of the real beneficiaries of the donations. Due diligence implies behaviors such as:

• Know the non-profit entities to which resources will be donated and check their background or alerts in restrictive lists or public information sources. 
• Refrain from giving gifts or courtesies to authorities or public officials, with the objective of unduly influence their decisions.
• Properly record donations, sponsorships or contributions to democracy in accounting systems.
• Before entering into agreements or contracts with the State or public authorities, we ask for legal advice to guarantee compliance with the applicable regulations.
• We reject the granting of bribes through third, such as agents, consultants, suppliers or other intermediaries of the company.
• Contributions, donations or sponsorships to charities, foundations, non-profit associations will always have a lawful purpose and will never serve to cover up bribes.
• Exceptionally, we can finance electoral campaigns as long as these contributions seek to promote democracy, are adjusted to current legislation and do not seek undue advantages for the company.

Studt some other cases and compliance lessons in the Annual Conduct Course, The Power of your Decision – Season 2, available on your Success Factors learning path.