Compliance Newsletter

408 words | 2 page(s)

The company is facing challenges with its Macau operations. This is because the island has the potential to reach out to a growing demographic of wealthy consumers in China. They have more disposable income and are seeking out a getaway that is close to the mainland. However, issues such as corruptions are becoming increasingly problematic, with it negatively impacting perceptions of the firm and those individuals they interact with. In many cases, these relationships are concentrating on the relationship among politically exposed persons. These are government officials and their direct relatives. The company is allowed to do business with them, but needs to maintain a sense of neutrality throughout the process. (Gray) (Oliveira)

According to the firm’s ethical policies and guidelines, all employees are required to treat everyone equal. This means that they are forbidden from engaging in a number of activities to include: engaging in practices that will direct business to the firm for certain favors and accepting any gifts / money. In the event these actions occur, everyone is required to report violations to the Compliance Officer and General Counsel. They will investigate and determine if the person engaged in inappropriate activities. If they conclude there is a violation of the policies, there are a number of penalties which can be assessed against them. The most notable include: fines, termination, criminal and civil prosecution. These areas are important, as they will help the company to specifically define prohibited practices and the impacts of breaching them. This serves as a way in helping to set the tone, atmosphere and practices of the firm. In the future, this will ensure that everyone is embracing the highest ethical practices. (Gray) (Oliveira)

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Clearly, politically exposed persons are a major threat to the company’s Macau operations. This is troubling, as it can eat away at the perceptions of the firm and the way it interact with stakeholders. Once this happens, is the point the entire organization could be subject to regulatory investigations into its practices. To prevent this, the firm’s policies are serving as a new approach. It is focusing on treating everyone equally. These guidelines will help employees to understand what behavior is prohibited, the consequences and long term effects. This is when it will create new standards that are embracing the highest moral and ethical practices. (Gray) (Oliveira)

  • Gray, Larissa. Politically Exposed Persons. Washington: World Bank, 2010. Print.
  • Oliveira, George. One Country, Two Systems. New York: Springer, 2009. Print.

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