What you need to know
Dentsu group prohibits bribery and corruption in all business dealings, in every country around the world, with both government and private sector parties. This summary provides an overview of the rules that must be followed to avoid behaviour that could be seen as bribery.
What are anti-bribery and corruption laws?
Our global business is subject to UK and a number of other national anti-bribery and corruption laws which have global reach. These laws, as well as local anti-bribery legislation, apply to all Dentsu group businesses and people wherever they may be located. The purpose of these laws is to ensure that business is conducted in an honest and fair way.
Why do you need to comply with these laws?
Everyone working for, or on behalf of, a Dentsu group company must comply with anti-bribery and corruption laws.
Essentially, employees must:
- not offer, give, receive or request a bribe; and take all reasonable steps to prevent others who are acting on our behalf, from offering, giving, requesting or receiving bribes.
- not offer or give an incentive of any kind to a public official which would cause them to improperly fulfil their function.
- not make any contributions that have a political purpose without the required authorisation.
Anti-corruption laws also require company management to ensure that adequate procedures such as establishing policies & procedures, internal controls and training initiatives are in place to prevent acts of bribery. Failure to follow anti-bribery laws and Dentsu group policies & procedures could subject our companies and employees to criminal charges, fines, and/or reputational damage.
How to spot bribery or corruption
A bribe typically involves promising, offering, giving, demanding or receiving a financial, or other advantage, for the purpose of influencing or rewarding someone to do something that is illegal, unethical and / or a breach of trust. A financial or other advantage could be a gift, prize, business opportunity, favour, commission, loan, cash, hospitality, service, discount, the award of a contract or anything else of value. Some examples of bribery include:
- making an unofficial payment to a government official to speed up a government decision (these are also called facilitation payments);
- providing gifts in exchange for winning or retaining a contract; and
- accepting gifts or hospitality in return for placing increased volume of business with a media owner.
Corruption is the abuse of power or authority for personal or corporate gain. Bribery is a form of corruption. Other examples of corrupt practices include, fraud, tax evasion, nepotism and money laundering.
What do you need to be aware of?
There are other Dentsu group policies which help us prevent bribery and corruption, such as the Business Gifts, Entertainment and Hospitality Policy.
Additionally, to help prevent the risk of bribery when dealing with third parties, employees should be wary of companies or individuals who:
- appear to engage in, or have been accused of engaging in, improper business practices;
- have a "special relationship" with foreign government officials;
- insist on receiving a commission or fee payment to ‘facilitate a service’ or carrying out a government process for us;
- request payment in cash and/or refuse to sign a formal commission or fee agreement;
- request that payment is made to a country or geographic location different from where the third party resides or conducts business;
- demand lavish entertainment or gifts before commencing or continuing contractual negotiations or provision of services;
- request that a payment is made to "overlook" potential legal violations; or
- request or require the use of an agent, intermediary, consultant, distributor or supplier that is not typically used by or known to us.
How can you report concerns or suspicions of bribery or corruption?
If you have any concerns about potential bribery or corruption, first raise these with your line manager or the Ethics & Compliance or Legal teams. If this is not possible, then contact our independent Speak Up service. The service is provided by Safecall Limited and is independent from Dentsu group. See the Speak Up Policy for more information on how to report concerns.
What can managers do to help?
Managers should actively support awareness and communication of, and compliance with, our global policies that provide guidance on how to prevent bribery and corruption, such as the Code of Conduct, our Legal Policy, our Business Gifts, Entertainment & Hospitality Policy, and our Conflict of Interest Policy. Managers should also make their team aware of the training options available for better awareness of this topic, and should contact Ethics & Compliance if they feel their team has a specific training need.
Need more information?
Refer to the full Anti-Bribery and Corruption controls within the Legal Policy for more details.