You work in Sales in the foreign country of Fauxnation. Anna, the president of one of your resellers, has approached you and said that she has a strategy for doubling sales before the end of the quarter. It turns out that Anna used to go to school with the wife of the CEO of Technology Now, Fauxnation’s largest company, which is headquartered in Fauxnation City. Technology Now is interested in purchasing  your company’s products as part of a major technology overhaul. In order to clinch the sale, Anna thinks that you should offer to fly the CEO and his wife first class to your company’s headquarters, to visit the Executive Briefing Center. Since it is “on the way,” they’d like to make a stop in New York City to see the tree at Rockefeller Center (the CEO loves Christmas trees) and to do some shopping. Anna also mentions that it would only be polite at holiday time to offer them gifts, and she recommends an iPad each for the CEO and his wife so they can keep in touch with their family while they are away.

What should you do? Because the situation is complicated and there is a real risk of appearing to bribe the CEO for Technology Now’s business, you need to seek advice from your manager and your company’s ethics and compliance office. They’ll explain what you can do to further your goals and the company’s interests without breaking the law or violating the company’s code of conduct (including policies aimed at preventing corruption and bribery).

With all of the corruption laws around the world, the primary thing to remember is that you need to avoid both actual corruption, bribery, and kickbacks, and also the appearance of corruption, bribery, and kickbacks. In this scenario, it may be okay to provide only the CEO (but not his wife) with economy class travel to the closest Executive Briefing Center. It probably is not okay to arrange for a stopover in New York City. It is definitely not okay to provide them with a very expensive gift like the iPad.

What if, instead of asking you to provide the trip and gifts, a reseller offers to provide these things? Everything stated above is still true. You should seek advice from your manager and your company’s ethics and compliance department. Even though your company is not directly engaging in activities that could be construed as corruption, bribery, or kickbacks, because someone in your company’s channel is engaging in the activity, your company will also be held responsible. This means that your company could end up paying massive fines and employees could end up in prison.

What if the gifts are iPods instead of iPads? Although iPods are much less expensive than iPads, they are still unacceptable if their value exceeds your company’s gift policy limit; even if they fit within the limit, they may still be unacceptable because the gifts are personal in nature.