Four Hallmarks of Permissible Gifts and Entertainment: Insight from PepsiCo and Paul Hastings

Providing gifts, travel and entertainment to business associates is a time-honored and legitimate means of promoting a company’s products and services and developing business relationships.  However, when foreign officials are involved, a company must be particularly vigilant to avoid crossing the line from appropriate business development to prohibited bribery and, as always, a company must accurately record gifts, travel and entertainment to avoid running afoul of the FCPA’s recordkeeping provisions.  A recent program hosted by the Ethisphere Institute and Thomson Reuters and featuring Nathaniel B. Edmonds, partner at Paul Hastings LLP and David Yawman, Senior Vice President and Chief Compliance & Ethics Officer of PepsiCo, Inc., addressed the appropriate parameters of gift-giving in the context of the FCPA, with a focus on four key “hallmarks” of permissible gifts.  See also “Gifts, Travel, Entertainment and Anti-Corruption Compliance: Sources of Authority, Best Practices and Benchmarking,” The FCPA Report, Vol. 2, No. 22 (Nov. 6, 2013).

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