In an interview published by The New York Times in February 1976, former Lockheed President A. Carl Kotchian defended the payment of bribes by the company as follows:

"Some call it gratuities. Some call them questionable payments. Some call it extortion. Some call it grease. Some call it bribery. I look at these payments as necessary to sell a product. I never felt I was doing anything wrong."

More than 30 years later, Reinhard Siekaczek, an accountant employed by Siemens who oversaw an annual budget for questionable payments in excess of $50 million, stated:

"I never thought I would go to jail for my company. ...We thought we had to do it. Otherwise, we would ruin the company. ...People will only say about Siemens that they were unlucky and that they broke the Eleventh Commandment. The Eleventh Commandment is, 'Don't get caught.'"

You have been hired to assist ABC Multinational Company to help educate employees on ethical practices and corporate culture. More specifically, related to the Foreign Corrupt Practices Act, your role is to prevent situations described in the above scenario.

• Explain what the employees should know regarding the Foreign Corrupt Practices Act.
• Provide examples of Foreign Corrupt Practices Act violations.
• Identify company actions or red flags that might indicate violations of the Act.
• List any consequences of the violations.
• Recommend actions to report possible violations.
• Describe protections for whistleblowers. Why are they important? How do the protections impact the Act?