Asis Electronics, a subsidiary of a European-based corporation

This case was written by David Wesley under the direction of Professor Henry W. Lane for the
purpose of class discussion. The authors does not intend to demonstrate either effective or ineffective
Copyright 2009 Northeastern University, College of Business Administration
Version: 10.2012
Peter Inge, controller for Asis Electronics, a subsidiary of a European-based
corporation, reviewed the contract for an order of transmitters for the ministry of
defense. Immediately, he noticed receipts totaling $6 million (approximately 20
percent of the total contract value) that did not seem to be attached to any equipment
or services provided by his company. Inge became concerned that Asis may have
over-invoiced the ministry and he approached the CFO about what to do. What plans
do you have with the surplus that is in our system? he asked. This topic is none of
my concern, the CFO replied.
Inge let the matter be for several months until he received the annual compliance
document for his signature. The form was part of an anti-corruption effort
implemented by Asis in the 1990s after a bribery scandal resulted in the convictions
of several high-level employees. The company also worked with the OECD on the
new , and it became a member of Transparency
International, a to reducing corruption around the
world. Many considered Asis to be one of the leading companies in the fight against
corruption. Asis encouraged its employees to report any irregularities to the
compliance department.
Every employee should be concerned with the good reputation of Asis in
each country. In all aspects of performing his/her job, every employee
must focus on maintaining the good reputation of, and respect for, the
To reduce concerns about potential repercussions for reporting irregularities, Asis
established protected communications channels that ensured confidentiality.
Inge read the compliance form and reviewed the
(see Exhibit 1), in particular sections 2 and 7, to see if he could find any guidance.
He wondered what he should do..
Page 2 *
Exhibit 1
Asis Anti-Corruption Handbook (Abridged)
Table of Contents
1 Gifts and hospitality
2 Payments for routine action (prohibited)
4 Company charitable donations
5 Sponsorships
6 Intermediaries
7 Record keeping and accurate recording
8 Acquisitions, joint ventures and minority interests
2 Payments for routine action (prohibited)
What is this about and why is it an issue?
They are small payments made to lower-level government or private sector employees, as a personal benefit to them, to
secure or speed-up the performance of a routine action to which the payer is entitled. These are sometimes known as
facilitating payments. These are an issue because:
They are a form of corruption.
Payments for routine action are illegal in almost all countries.
Paying for routine government action could easily open the door to more serious issues of corruption.
What is the Asis policy?
Asis prohibits payments for routine action.
What does this mean in practice?
If you make a payment that could possibly be misunderstood as a payment to facilitate routine action, you must notify
your responsible Compliance Officer and make sure that it is properly documented and posted to the correct account.
Escalate to your responsible Compliance Officer when you encounter anything that looks like a request for a payment
to facilitate a routine action. Such practical problems do arise in everyday business in some countries, but there are
usually other ways that Asis can solve these kinds of issues.
Never attempt to disguise such a payment as something else. The penalties for disguising such a payment are much
greater than the penalties for making one!
How do I go about getting approval?
Approval will not be given.
7 Record keeping and accurate recording
What is this about and why is it an issue?
Books and records is a general term used in this guide to describe all business records. It includes accounts,
correspondence, memoranda, tapes, discs, papers, books and any other documents. It is important because the various
legal codes require that we maintain accurate and complete books and records. In order to combat corruption it is
important that transactions are transparent, fully documented and coded to accounts that accurately reflect their nature.
Attempting to conceal a payment can create a worse violation than the payment itself.
What is the Asis policy?
Asis books and records must be kept with reasonable detail and accuracy so that they correctly reflect all transactions.
All controls and approval procedures must be followed.
Asis books and records must not contain any false, misleading or other artificial entries.
What does this mean in practice?
Ensure that all your own transactions are fully documented, correctly approved and coded to the correct expense
If you are aware or suspect that anyone is directly or indirectly falsifying the books and records or in any other way
attempting to disguise a payment, you must report your concern immediately to the Compliance Helpdesk Tell Us.

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