When providing anti-corruption training, what kind of programme do you believe is most effective?
We will initially discuss our proposal with the company’s general counsel, and follow it up with face-to-face training with employees, in special seminars. By using seminars, it allows employees to ask us questions, which we can then feed back to the company. It’s also important to get the company’s senior management involved in any anti-corruption training programme. Unless a compliance training programme has head office support, it can be very difficult for local management to persuade their local employees to take the issue seriously. In China, we will often provide an outline of both Chinese anti-corruption law and the FCPA in the same meeting. Some practices that are permitted under Chinese anti-corruption law are not permitted under the FCPA, so there are a lot of grey lines we have to discuss. US law tends to be more restrictive about what companies can and cannot do, especially when a company is dealing with government employees or related enterprises. Most Chinese employees un
