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Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
Senior Editor

Bill Steinman
Senior Editor

Richard L. Cassin
Editor at Large

Elizabeth K. Spahn
Editor Emeritus

Cody Worthington
Contributing Editor

Julie DiMauro
Contributing Editor

Thomas Fox
Contributing Editor

Marc Alain Bohn
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Bill Waite
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Russell A. Stamets
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Richard Bistrong
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Eric Carlson
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Benchmarking Alert: Here’s General Motor’s full anti-corruption policy

Last year, General Motors produced over 6.8 million vehicles and employed over 150,000 people. Here are five interesting points from its global anti-corruption policy.

1. All bribery is prohibited, even if you don’t think it’s wrong. 

GM prohibits all bribes, including conduct you may not consider a bribe or even improper, but fits a legal definition of corruption.

2. A well defined list of valuables. 

Anything of Value: Anything that might have value to the recipient, including cash or cash equivalents (e.g., gift cards), gifts, gratuities, goods, loans, discounts, cars (including loaner, discounted, and “test drive” vehicles), entertainment or tickets, meals or drinks, travel or lodging, charitable contributions, political contributions, training, services, personal favors, paying bills for others, forbearances, offers of employment, hiring someone’s friend or relative, or anything else that is valuable to the receiver, even if it would not be valuable to anyone else.

3. Figure out if you are dealing with a government official. 

It is your responsibility to understand whether you are interacting with a government official – either a U.S. official or a non-U.S. official – and to comply with applicable law and GM policy.

4. No facilitating payments, ever. 

A facilitating payment is a payment of small value made to low level government employees to obtain a non-discretionary, routine governmental action to which GM is legally entitled. While permitted under U.S. law in narrow, strictly defined circumstances, even very small facilitating payments may violate the U.K. Bribery Act and local statutes. Accordingly, this Policy strictly prohibits all facilitating payments.

This is similar to Apple, Novartis,  MicrosoftVolkswagen, and Airbus which ban all facilitating payments. Coca-Cola and Tesla might approve some facilitating payments. Walmart doesn’t mention facilitating payments at all.

5. Extortion needs to be accurately recorded. 

Extortion payments are payments that are necessary to ensure the health or safety of GM employees or of Third Parties associated with GM, including payments to avoid imminent physical harm or imminent illegitimate detention. Threats of purely economic harm are not extortion. Although extortion payments are permitted by this Policy, this is a very narrow exception that requires legal analysis. You must obtain approval from your RCO or another member of GM Legal before making such a payment, and you must report any extortion demand to your Managing Director immediately, whether or not you seek to make a payment, unless it is not possible to do so. If it is not possible to report the demand and seek approval for any payment as just described, the incident must be reported within one (1) business day, absent physical or technological impossibility. Extortion payments must be accurately recorded in GM’s books and records.

Microsoft’s anti-corruption policy is the only other one where we’ve seen extortion mentioned.

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View more anti-corruption policy benchmarks here.

Click here to view the General Motors Global Integrity Policy

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