Compliance IQ Test

A customer is very happy with the superior service provided by Rubis. Said customer offered a gift to the sales executive. The gift is a seven-day-stay at Sandals Royal Caribbean (SRC). Ordinarily, the sales associate would stay at a more affordable hotel on a weekend when vacationing locally. The gift was happily accepted and the hotel was nicely enjoyed. Is there a violation?

There is no violation. The customer is expressing her appreciation and it is customary to tip when good service is provided.

There is no violation if the sales executive most likely could afford to stay at SRC.

There is a violation of the gift policy.

An employee of Rubis was offered to serve on the board of directors of a major vendor. The employee was honored and happily accepted the offer. What is the violation?

There is no violation! Employee affairs are no concern to Rubis outside of normal working hours.

This is a conflict of interest.

There is no violation and the employee has the opportunity to help Rubis reduce operating cost.

You come to work and noted a colleague is not following the established Company policies or procedures. The employee justified their action by saying, “if there is a quicker and easier way why not do it”? How would you respond?

Scold the colleague and report the matter to his/her friend.

Train the staff on what should be done.

Encourage the employee to follow the policies and procedures and advise the department manager, any HOD or the Compliance Advisor of the incident.

New international sanctions have been decided against a foreign country in which one of my suppliers is based. How do I know if my relationship with this supplier is affected?

The sanction was levied against the country and not the supplier so no action is necessary.

Your relationship with this supplier might not be impacted as sanctions can be limited to specific individuals, entities, products, or activities. Nevertheless, ask the advice of your Compliance Advisor, who will help you confirm on a case-by-case basis that your supplier is not affected by the new sanctions.

Reach out to your supplier and seek their assurance they are not impacted by the sactions.

In the context of an administrative process, a public official blocks my request and makes it clear to me that the procedure will progress quicker if I pay him a certain amount of money in cash. What should I do?

Pay the public official the cash especially if the approval is urgently needed and crucial to the Company's operations. The benefits will outweigh the cost.

Pay the public official using another mode of payment.

The public official is asking you for a facilitation payment. In this specific instance, refuse the request and indicate that your Company and the regulations do not allow unofficial payments. Then, report the incident as quickly as possible to your Managing Director, any HOD and your Compliance Advisor.

I plan to invite a client to lunch for an annual review. However, the customer has just published a call for tenders in which we are going to participate. Can I still invite the client?

Context is a factor to be taken into account when sending gifts or invitations. In this case, it is better to postpone your lunch plan and organize a meeting at the office to review the past year.

You may still invite the client to lunch providing you found out about the tender after your invitation. This shows the invitation was made with pure intentions.

If the value of the lunch is small, even if you have knowledge of the tender you are still allowed to invite the supplier.

I work in my entity’s Purchasing Department. We have launched a call for tenders and the company in which one of my family members works has submitted an offer. What should I do?

Do nothing.

Report the issue to your Manager only if the tender value if material.

Report the situation to your Manager. Your Manager will determine whether your family relationship could conflict with the interests of your entity. If so, you will have to let your Manager and colleagues manage this tender without your involvement.

During a delivery by one of my usual suppliers, he notices that part of the order is missing. He asks me to sign the delivery slip and tells me that he will deliver the rest of the order within a week without fault. What should I do?

Sign the slip! You do not want to create an unnecessary risk of damaging the relationship with the supplier.

The supplier made a honest mistake. Sign the slip but actively follow-up to ensure the remaining order is delivered as promised.

Knowingly signing incorrect invoices or delivery notes can be seen as fraud, damage the Group’s image and put you at risk of sanctions. Do not sign it and ask the supplier to fill out a delivery note that reflects the quantities delivered. In addition, inform the Department Manager.

During an industry meeting, a person discusses the commercial margins connected with a product. What should I do?

It is strictly forbidden to share sensitive information (prices, costs, sales volumes, business strategies, etc.) with competitors. You must leave the meeting immediately, request that your departure be formally recorded and inform your Manager and your entity’s Compliance Advisor.

You are allowed to disclose the information as it is not defined as "sensitive" in the Group's policies.

You may disclose the information providing the other person provide similar information in return and the Department Manager is informed.

I have just recruited a new employee to my team, previously employed by a competitor. He offers to share the detailed business strategy of his previous employer. What should I do?

Accept the information if it is beneficial to the Company.

Remind the employee that the use of confidential information regarding the former employer is prohibited and remind your colleagues that they should not solicit this type of information.

Confidential information involving a former employer is allowed. Ensure the employee agrees in writing to supplying the information.

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