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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
Contributing Editor

Bill Waite
Contributing Editor

Shruti J. Shah
Contributing Editor

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

Benchmarking Alert: Burberry’s high-class anti-bribery policy

The London-based luxury brand is highly-regarded for its stylish clothes and cheerful bags. Founded in 1856, Burberry has become one of the most sought after high-end retailers in the world. How sweet is the aroma of its anti-bribery and corruption policy?

1. The FCPA is curiously absent. 

The UK Bribery Act is intended to support international efforts to combat bribery, corruption and facilitation payments. The Act applies to all UK companies wherever they operate in the world.

2. A warning about respondeat superior. 

Burberry may be held responsible if its Business Associates pay bribes to obtain or retain business or some other benefit for Burberry. This is regardless of whether Burberry was aware of this activity and regardless of where in the world this activity takes place.

3. It’s a “no” for facilitation payments. 

Bribery, corruption and facilitation payments are unethical, illegal and against Burberry’s Policy. Companies and individuals can be prosecuted by regulators in the UK for engaging in these activities.

This is similar to Disney, Unilever, Carlsberg, Apple, Novartis, Microsoft, Volkswagen, Airbus, GM, 3M, and Pfizer that all ban facilitating payments. Coca-Cola, Tesla, and ExxonMobil might approve some facilitating payments. Walmart doesn’t mention facilitating payments at all.

4. A realistic view on gifts. 

Business Associates are discouraged from giving or receiving gifts or hospitality with any parties with whom they have a business relationship, or intend to do business. However, Burberry recognizes that in the luxury business there are occasions when exchanging gifts or hospitality may be appropriate. For example, gifts and hospitality may be appropriate in connection with marketing and public relations activities or to acknowledge an event.

5. The seven-step gift evaluation process. 

In particular, Business Associates must always ensure that any such exchanges are transparent, proportionate, reasonable and bona fide. If the Business Associate answers ‘yes’ to any of the following self-approval questions then the exchanging of gifts or hospitality in the circumstances is probably inappropriate.

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View the full four-page Burberry anti-bribery and corruption policy.

View more anti-corruption policy benchmarks here.

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