Summary of the company: The Country, Gampelova : Located in Eastern Europe Recently admitted to the European Union Estimated population of 15 million; expected to grow by 2% annually over the next five years Socio-economic data: nominal GDP per capita = US$5,500 (projected to grow 4% annually over the next five years), Unemployment rate: 15%, Adult literacy rate: 90% Corruption is rampant, with bribery equivalent to 10% of GDP. The government does not diligently investigate and prosecute bribery cases. As much as US$500 million has been subject to waste or theft. Government officials are largely responsible for the disappearance of this money. The Project: For the design, construction, and maintenance (DCM) of nationwide 5G network If completed, the Project would be the largest infrastructure project in Gampelova's history Existing 4G network (and predecessor cellular networks) are owned and operated by the government. Only 45% of the urban population and less than 10% of the rural population has access to 4G network; 4G network has exhibited operational failures, inefficient energy use, and data security vulnerabilities There are no Gampelova-based companies with 5G DCM capacity. The government is willing to consider foreign bids provided that the new 5G network will: be protected from disruption or manipulation by foreign entities, have the capacity to support the country's projected population growth and economic strategy, ensure reduced energy consumption, and provide employment opportunities for Gampelova residents. The Project will require contractors, sub-contractors, and suppliers (from any combination of foreign and local companies) and extensive government licenses at all stages The Project will be open to blind bidding by three foreign companies

CBC Co. is a privately-owned Chinese company headquartered in Shenzhen. The company has extensive experience in the design, construction, and maintenance of cellular networks throughout Eastern Europe as well as in China. The company has a rapidly improving reputation for the quality of its DCM services. The company sometimes selects subcontractors on the basis of political connections and factors other than quality of work and price, and its due diligence screening process for subcontractors or intermediaries has only been recently implemented. The company has a long and detailed code of conduct and includes provisions requiring compliance with all applicable anti-corruption and data protection laws in its DCM contracts. The company recently started conducting anti-bribery training for its officers, employees, and third parties but has not yet implemented a data protection compliance program

1. What ethical/CSR and legal considerations do you believe apply to your Company in connection with the Project -- including, but not limited to, anti-corruption and data protection? (In answering this question, among other things, please address the U.S. Foreign Corrupt Practices Act (FCPA), the EU General Data Protection Regulation (GDPR), and the California Consumer Privacy Act (CCPA). If any of the FCPA, GDPR, and/or CCPAapplies to your Company, explain how; if it does not, explain why.)
2. Taking into account your response to these questions, what actions do you advise the Company to take in order to win the bid for the Project and why?