19.10.2018

It is important to know that prohibitions of bribery do not concern only monetary bribes. Instead, they involve anything of value or any benefit that can exert undue influence on a public official who has discretion over providing a business advantage.

Non Monetary Forms of Bribery
	·         Travel and lodging not directly related to business activities (such as providing for a detour to a tourist destination on a business trip or paying expenses for a government official’s family members)
·         Providing excessive (value and frequency) gifts and entertainment
	·         Hiring a government official’s relative
·         Making a charitable contribution, even to a bona fide charity, if that contribution benefits a foreign official or is part of a quid pro quo

SOURCE: BRIBERY & CORRUPTION, (ED.) JONATHAN PICKWORTH AND DEBORAH WILLIAMS, GLOBAL LEGAL GROUP, 2013

All these manifestations can also be met by employees in various small and medium-sized enterprises.

The anti-corruption compliance program can help the organizations to prevent these manifestations.

Notably, there is already a Draft Criminal Code of the Republic of Armenia, which provides for criminal liability for legal entities. In parallel, it is envisaged that such liability will be avoided if legal persons have taken appropriate measures and this may be  the basis for implementation of the anti-corruption compliance program.