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DECEMBER 2015 BRIEFING
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SH INTERNATIONAL LLC


DECEMBER 2015 BRIEFING


A Holiday Guide to Gifts and Bribes
 
Dear Clients & Friends of SH International:
 
The holiday season is a good time of the year to ask yourself the question:
 
What is the difference between a gift and a bribe?
 
Knowing the answer could keep you out of jail.
 
Happy Holidays!
Gift Giving DO’s and DON’Ts
Gifts versus Bribes
 
A bribe is a gift given in order to illegally or dishonestly get someone to do something for you or for your company. The following are some suggested DO’s and DON’Ts to help you through the often murky waters of what differentiates a gift from a bribe.
 
DO read about the U.S. Foreign Corrupt Practices Act (FCPA). It has a provision making the bribery of foreign officials with personal payments or rewards illegal.  It uses a pretty inclusive definition of “foreign official.”
 
DON’T ignore the FCPA. Check out this recent example of what could happen if you do. Spoiler: Miami, Venezuela, jail time, millions in penalties.

DO put in place guidelines for giving and accepting gifts for your employees. There is no universal set of rules. With the FCPA, it has more to do with intent than materiality. Establishing and enforcing guidelines takes the guesswork out of the process for your employees.  
 
DON’T give gifts that have to be kept “under the table.” If the receiver will not be able to be transparent about the gift, it is better not to give it.
 
DO know that in many other countries, people view the lobbying process in the U.S. as akin to bribery, and view the U.S. stance on bribery as hypocritical. So while it is critical to be clear that you do not give or accept bribes, this subject may not be the best icebreaker at a holiday party.
 
DON’T solicit or coerce the giving of gifts to yourself or to your employees.
 
DO consider giving appropriate gifts. Gift giving is a more common business practice in many emerging markets, given the critical importance of showing that you value your relationships.
A Gift For You to Share
Executive Coaching
 
Some of our clients “hands us the keys” on their emerging markets business expansion plans. They expect us to offer concrete and viable plans, and to skillfully implement them. We are still mindful to check in with them at critical points along the way, to make sure that we are implementing in accordance to their preferences and goals.
 
Other clients prefer to use our services to perform specific tasks that they have already envisioned as part of their growth strategy.
 
On the opposite side of the spectrum is the “do-it-yourself” client: an entrepreneur, business owner or leader who wants to be hands-on in every aspect of their global business growth. However, often facing new business and professional challenges, they pragmatically decide to get some guidance along the way from someone who understands many of the issues that they will face.
 
For these clients, we offer an executive coaching service
 
We have a gift for you to give. If you sign up for our standard six-month “unlimited” coaching package before the New Year, you can give a one-month package to your favorite global entrepreneur, business owner or leader. Contact us to learn more.
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ABOUT SH INTERNATIONAL LLC

We expand businesses through emerging markets deals, ventures and initiatives. We leverage a proprietary network of resources, specialists and partnerships to achieve powerful results. Based in multilingual and practical experience on five continents, we provide your company with truly global vision.
 
Copyright © 2015 SH International LLC, All rights reserved.


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