Business Integrity. ; Cases and

The COWI Group COWI A/S Parallelvej 2 DK-2800 Kongens Lyngby Denmark Tel +45 45 97 22 11 Fax +45 45 97 22 12 www.cowi.dk Business Integrity. Cases and Dilemmas, Examples Table of Contents 1 2 3 3.1 3.2 3.3 3.4 3.5 3.6 3.7 3.8 3.9 3.10 3.11 3.12 3.13 3.14 3.15 Background and purpose Overall advice Cases and dilemmas Services included in a proposal Support of a humanitarian activity during a bidding process Engaging an Agent Friendly relationship with a supplier No payment for extra works Payment of fee note by third party Handing over of supervision cars Entertainment during a study tour Employment of client's son Suspicion that the contractor is bribing the client Pressure from a client to accept a non-conditional bid Speed up Customs Clearance Giving a gift to a client Sub-consultant nominated by the client Entertainment/benefits offered by a supplier of computer software 1 2 2 2 3 4 5 6 7 8 8 9 10 10 11 11 12 13 1 Background and purpose One may wonder why we need this document, when COWI has a Code of Conduct and a Corporate Practice in Business Integrity, including a Business Integrity Policy. However, we need to ensure not only that our values and policies are prepared and made available, but also that we all have the same understanding on how they should be understood and applied. We have to realise that there is a 'grey area' where we have to take so many things into consideration that fixed rules not are desirable or possible. The purpose of the document is to assist you in making the right decision in the 'grey area' in accordance with the Business Integrity Policy. The cases and dilemmas presented in this document are covering the 'grey area' only. These are Date of issue 5 Apr 2004 Prepared TJ/DG/JJA/VR/TSJ D:\Docstoc\Working\pdf\83e51556-90c7-4fa4-8d49-a04ec422b2d1.doc Business Integrity, Cases and Dilemmas 2 / 14 situations which could swing either one way or the other depending on the detailed circumstances. This document is intended to stimulate thoughts about how certain dilemmas can be approached and what principles need to be taken into account. Asking questions, presenting dilemmas, and discussing these, rather than elaborating fixed rules, leads to a more open climate where people are willing to admit that certain situations could swing either one way or the other. The document is a supplement to the Corporate Practice in Business Integrity, and the cases and dilemmas presented should be read in conjunction with that document. The cases and dilemmas are fictitious, but developed by colleagues in COWI, based on situations from the consulting industry. The collection will be supplemented and adjusted as experience is gained. Please observe that these are examples only and will consequently not cover all possible situations. 2 Overall advice Whenever you are dealing with a situation in the 'grey area' please observe the following: 1. The underlying reason for the transaction you plan to carry out must not be to try to influence that a person fail in his/her duty. Ask yourself the following question: Would I mind reading about this transaction in tomorrow's newspaper? If the answer is 'Yes', refrain from doing it. Seek advice and discuss the transaction with your superior or alternatively a peer. If you go along with the transaction, please make sure that it is transparent and that proper documentation is available. 2. 3. 4. 3 Cases and dilemmas Scenario 1 3.1 Services included in a proposal In the proposal on a World Bank financed project it is stated that the client will get three paid trips to COWI headquarters in Denmark and the project will provide the client with five PCs including Internet access. The Terms of Reference do not explicitly mention travel and PCs. Is it acceptable to have these statements in the proposal? Q&A D:\Docstoc\Working\pdf\83e51556-90c7-4fa4-8d49-a04ec422b2d1.doc Business Integrity, Cases and Dilemmas 3 / 14 If the travel expenses and the expenses for the five PCs cannot be justified to add value to the project, they constitute a hidden benefit or gift, and consequently it is not acceptable to include these items in the project. If services and deliverables included in a proposal can be questioned to be within the Terms of Reference, they must always be justified. Example of justification for the travel expenses could be transfer of knowledge or a training course (an outline of a training program may be included in the proposal). Example of justification for paying the PC and the internet access could be to facilitate communication and hereby saving travel expenses i.e. a cheaper project. Scenario 2 After the job is completed the PCs are left with the persons who worked with the PCs on the execution of the project. Is it acceptable just to leave the PCs with these persons? The PCs belong to the project as any other supplies bought on the project account. All such supplies (inclusive of written transfer documentation) shall officially be handed over to the client as a part of the project handing over process, also the PCs, and consequently it is not acceptable just to leave the PCs with the persons without a specific handing over agreement. Q&A Scenario Support of a humanitarian activity during a bidding process A COWI employee participates in a delegation journey to a country in South East Asia known to have a high level of corruption. During the visit, meetings are arranged with important local clients, one of whom is the Ministry of Works and Infrastructure. During the visit, participants in the delegation decide to contribute financially to the construction of a nursery school. The contribution is beyond what COWI accept as the normal range for gifts. 3.2 Q&A Is it acceptable that COWI contributes to the nursery school? The contribution is a pure business decision as long as the contribution is to a humanitarian activity, and there are no indications of political undertones. Consequently, it is acceptable from a business integrity point of view. Modified scenario A few weeks prior to the visit, COWI submitted a proposal for an infrastructure project. The project is financed by Asian Development Bank. Is it still acceptable to contribute to the nursery school? The following aspects need to be considered:  Could a contribution be considered to unduly influence the selection of consultants for the infrastructure development project? Q&A D:\Docstoc\Working\pdf\83e51556-90c7-4fa4-8d49-a04ec422b2d1.doc Business Integrity, Cases and Dilemmas 4 / 14  Will refraining from a contribution be considered so impolite that it will be a disadvantage during the selection process? The situation with the submitted proposal changes the situation a bit. COWI may be accused by the other bidders to try unduly to influence the selection process. A contribution under these circumstances should be carefully considered. If it is decided to contribute, COWI's contribution should be on the same level as that of the other contributions or lower. COWI should under no circumstances give a contribution, which is substantially higher than that of the others, or contribute at all if COWI is the only contributor. Scenario 1 3.3 Engaging an Agent COWI signed an agent agreement a few years back in country A with the objective of developing COWI's position within the water and sanitation sector. The agent was and is a well-established business man with a good reputation in the local business society and with good relations to key officials in the ministry responsible for water and sanitation sector. The scope of the agreement is defined to services related to i) general market intelligence, ii) specific logistical support, and iii) recruitment of support staff for specific projects. The agent is reimbursed for his operational costs and is in addition awarded a fee of 3% of COWI's fee of projects awarded. Q&A Is this agreement acceptable? It is a matter of concern that the agreement contains open ended operation costs in addition to the 3% fee. This should only be accepted under the condition that full documentation of the operation costs is provided. It would be preferable to have the percentage fee graduated corresponding to the size of the contract (4% seems to be OK for a contact of MDKK 1, but too high for a contract of say MDKK 50). Scenario 2 The open ended operation costs have been solved. COWI wins a contract financed under a loan from Asian Development Bank. The consultancy services are only related to capacity building of government staff engaged with rural sanitation and health & hygiene promotion. At the same time the agent develops his business further so he also represents a Korean pump manufacturer supplying water supply pumps to big urban projects undertaken by the same ministry who is responsible for COWI's contract. Q&A Is it acceptable to continue with the agent? The key issue here relates to conflict of interests. The main question is: Is the agent's business relationship with the client by representing a pump manufacturer of such a nature that the agent could be suspected of influencing the decision process related to the projects on which COWI has been bidding. D:\Docstoc\Working\pdf\83e51556-90c7-4fa4-8d49-a04ec422b2d1.doc Business Integrity, Cases and Dilemmas 5 / 14 If the agent's business agreement with the Korean pump supplier is clearly defined to markets outside the scope of services of COWI's consultancy contract, and hereby meets the requirements of ADB's procurement guidelines as stated in COWI's contract, then the agent agreement is acceptable. However, COWI should inform the client about the agent agreement (in order to ensure transparency), and the possible conflict of interests should be clearly explained. Scenario 3 A new COWI project opportunity has materialised where the scope of services are broad within the rural water and sanitation sector. Supply of pumps from the Korean supplier might not be relevant. A new agent agreement is to be established to cover any future cooperation, including possible new assignments within the urban water sector. The COWI standard format is to be used. The agent is in agreement to all clauses but would prefer to sign the contract in the name of a new company owned by one of his partners. This is done to avoid any conflict of interests between his agreement with COWI and the Korean partner. Is this an acceptable arrangement? The agent's desire to change name and signatory of the agreement is a matter of concern. A proper due diligence of the agent needs to be performed prior to conclude this arrangement. If the due diligence reveals that the agent is not able to render probably and eventually to document that he is able to completely separate the activities, COWI should not accept the proposed construction and must require from the agent to choose between COWI and the Korean pump manufacturer. However, if the agent is able to provide reasonable evidence that he is able to handle these conflict of interests and at the same time operate in accordance with COWI's Business Integrity Policy, the arrangement could be accepted. COWI should thoroughly consider whether the client should be informed in order to secure transparency. However a proper and thorough documentation should be kept on file. Q&A Scenario 3.4 Friendly relationship with a supplier A COWI employee (C) was previously employed as sales manager with a supplier (S). In depth technical knowledge about some of the products being manufactured, supplied and installed by S as well as knowledge about technical solutions related to interfaces to S's products was the basis for employment with COWI. COWI needed expertise in this field. C is convinced that S's product in many cases is the best possible solution for the clients. S has once a year a business seminar for customers and business relations, often some 75 participants. S has asked C to give a 20 minutes presentation under the topic: "Consultant's Role", and later in the afternoon to sit on the panel and an- D:\Docstoc\Working\pdf\83e51556-90c7-4fa4-8d49-a04ec422b2d1.doc Business Integrity, Cases and Dilemmas 6 / 14 swer questions. Since there appears to be an overlap between S's customers and COWI's potential clients C sees some marketing opportunities by accepting the invitation. No doubt, it is certainly in COWI's interest to be visible in this forum. C will book the time spent on relevant COWI account, and the three bottles of red wine from S will be enjoyed by C and his family. Q &A Is it acceptable to provide this assistance? If C's presentation is of general nature and not a sales talk for S's products, this is acceptable. C shall avoid recommending S's products or give the impression that he has a preference for S's products. However, C's previous close relationship with S is a matter of consideration. This previous involvement may be considered by the potential clients to affect C's impartiality and hereby C/COWI could be suspected of receiving kickbacks from S. From a detached point of view there is no doubt that C has maintained his impartiality as a consulting engineer. The main question is however, what the participants judge as the truth and choose to believe. If the participants could get the impression that C' is not impartial, C should refrain from participation. Q&A Does it matter if no overlap exists between S's customers and COWI's potential clients? This will not change the situation. Modified scenario S invites C to a special seminar for selected customers and business relations, 10 persons, to take place at a Michelin *** restaurant. S indicates that C shall act socially and at the same time flavour the conversation with technical expressions. C will of course be presented as an independent consultant. Is it acceptable to provide this assistance? This will not change the situation. Q&A Scenario 1 3.5 No payment for extra works A project for a municipality is progressing according to budget and the time schedule. When the project is about to be completed the payment for some agreed extra services cause trouble for the client's project manager. The project manager is satisfied with the services delivered by COWI. However, he has not in due time informed the financial committee of the municipality that the extra services will result in an extra cost of DKK 147.000. COWI has had an excellent relation to the client's project manager over the years, and he has always treated COWI fairly and friendly. No one questioned that COWI is entitled to the extra payment. The client's project manager is asking COWI to waive the fee related to the extra works. D:\Docstoc\Working\pdf\83e51556-90c7-4fa4-8d49-a04ec422b2d1.doc Business Integrity, Cases and Dilemmas 7 / 14 Q&A Should COWI accept not to get payment for the extra work in order to keep the good relationship with the municipality? Provided that no individual will unduly benefit from this and that the discount is offered to the municipality, such a discount is not in conflict with the Business Integrity Policy. In this scenario the key issue is that it is our assessment that no individual will unduly benefit from the withdrawal of the fee note (no doubt the client's project manager will benefit from the withdrawal, but the benefit is deemed to be within normal business practice and consequently not unduly). Hereby, the decision is purely commercial, and there may be special circumstances where commercial considerations may justify waiving such a fee note. Such an issue must always be discussed with the Business Unit Manager. If the considerations end with withdrawal of the fee note, the financial committee of the municipality must be informed that COWI has waived the fee note. It is not sufficient only to inform the project manager. Transparency and full documentation of the financial transactions must be ensured. Scenario 2 COWI decides to refuse to withdraw the fee note and the client's project manager is approaching COWI again telling that he will lose his job, if the fee note is not withdrawn? Does this new information change the situation? Withdrawal of the fee note will give the project manager a substantial personal benefit (he will keep his job). Hereby we may have unduly influenced the project manager's future decisions. He may fail in his duty by taking decisions under the assumption that he owes COWI something. With such information the fee note cannot be withdrawn. The key issue in this scenario is that the benefits are personal and they are substantial. One should bear in mind: It is binding to have knowledge. Q&A Scenario 3.6 Payment of fee note by third party COWI is consultant to a contractor on a job for the Ministry of Housing. The project manager in the ministry needs some help in relation to purchasing a house. One day the contractor asks COWI to assist the project manager of the Ministry to perform technical investigations on the house and the contractor tells that the invoice for the services shall be addressed to and paid by the contractor. Q&A Is it acceptable to provide this assistance? IF our client, the contractor, instructs COWI to provide services within our normal scope of work, we will provide the services and send the invoice to our client - the contractor. However, the red flag in this case is that there are basi- D:\Docstoc\Working\pdf\83e51556-90c7-4fa4-8d49-a04ec422b2d1.doc Business Integrity, Cases and Dilemmas 8 / 14 cally two options: a) the project manager has as a private person asked the contractor to assist him with his house under normal commercial conditions, b) the project manager and contractor has agreed that the assistance in relation to purchase of the project manager's house will be paid through the job for the ministry. If we have no further indications of illegal activity we should perform our services according to our normal business procedures, but be particularly careful to ensure that our transactions are transparent and documented. However, if it is obvious that the contractor considers this to be something which not should be disclosed, then we should refrain from participating in this activity. Scenario 3.7 Handing over of supervision cars On a project financed by World Bank, COWI has in accordance with the agreement procured a few cars to be used by the consultant for supervision purposes. When the project is well under way the client's contact person on site informs the COWI representative that the cars also need to be available to the client's project staff. This is not stated in COWI's agreement. Is it right to accept the requirement? On a single case basis this is acceptable as a friendly gesture, provided it is clear that COWI's duties are not negatively affected due to lack of transport. Q&A Modified scenario COWI's representative considers that the project will run into major difficulties, if a request for general availability is not met, and accepts to make the cars available to the client's officials. After two weeks the cars are no longer available for the project. Is it acceptable to procure two new cars under the World Bank grants without telling World Bank the true facts of the case? It is not acceptable to procure new cars without the approval of the World Bank. COWI should inform the World Bank of the situation and in collaboration with the bank decide how to handle this. Q&A Q&A Does it matter if COWI pays the two new cars? Certainly it matters. COWI should not procure any cars to remedy this situation, and COWI may be blamed by the World Bank to have made these cars available to the client's officials. By procuring new cars COWI may have accepted an attempt to conduct fraud and indicate that COWI is prepared to cover up. Scenario 3.8 Entertainment during a study tour In connection with a major project, a study tour to Holland with participation of both officials and consultants is arranged. The official in charge informs COWI D:\Docstoc\Working\pdf\83e51556-90c7-4fa4-8d49-a04ec422b2d1.doc Business Integrity, Cases and Dilemmas 9 / 14 that the expenses in connection with the participants spending the weekend in Amsterdam are to be paid by the project. COWI receives subsequent certification of the expenses. Q&A Is this an acceptable action? As administrator of the project account COWI is entrusted with the responsibility to ensure that only relevant expenses are allocated to the account. The client must have confidence that COWI fulfils this obligation with reasonable skill, care and diligence. Expenses related to a weekend in Amsterdam cannot normally be considered as relevant to the project. The action is not acceptable and the client's representative must be informed accordingly. Q&A Does it matter if calculations show that the total costs for staying during the weekend are lower than the total costs by leaving Friday night (lower air fare tickets)? This is an acceptable action, provided pure entertainment costs are paid by the participants themselves and it has been arranged prior to commencement of the study tour. Scenario 3.9 Employment of client's son A former COWI employee (A) holds a job in a government office. The office has considerable influence, and COWI is providing many services to the department. A's son has completed his m.sc. in engineering, but has difficulties getting a meaningful job. The son approaches the head of the relevant department in COWI asking for a job mentioning who his father is. Should COWI employ the son? It should neither be an advantage or a disadvantage that he is 'his father's son'. The son should be engaged if his qualifications meet the professional needs of the department and based on his personal character. Q&A Q&A Does it matter if it is the former employee, who contacts COWI (head of department) and not the son? This will not make any changes in terms of engaging the son. This should be based on a professional judgement only. However one should consider whether the former COWI employee seems to use his contacts in a questionable way/or he has normal fair intentions. If the son is not engaged, it should be considered also to inform the former employee of the reason for this in order to maintain the good relations with the government office. Q&A Does it matter if the former employee in addition to contacting the head of department also contacts the managing director? No. D:\Docstoc\Working\pdf\83e51556-90c7-4fa4-8d49-a04ec422b2d1.doc Business Integrity, Cases and Dilemmas 10 / 14 Scenario 3.10 Suspicion that the contractor is bribing the client COWI is performing consultant services, including supervision, on a major construction job with several contractors involved for the Ministry (the client). A COWI employee suspects that the project manager of one of the contractors is paying bribes to the person in the client's organisation approving change orders. The suspicion is based on the fact that quite a few change orders from that particular contractor are accepted by the client against COWI's advice and to an extraordinary high price. Should the COWI employee inform his counterpart in the client's organisation? If an employee gets such a suspicion, the employee should contact his superior in COWI, and they will together decide how to act. Prior to approaching the client we need to be sure that COWI's advice and cost estimate can meet a third party review. If the services provided by COWI can meet such a review, the client should be approached in an appropriate way. Q&A Q&A Does it make any difference if the employee has been present when the contractor and the client have discussed and agreed on fraudulent businesses? No, the client should be approached, but there is no need to make an internal review. Scenario 3.11 Pressure from a client to accept a non-conditional bid COWI prepares tender material, and conducted the tendering process in accordance with EU's rules for tendering. COWI evaluates the bids received according to the criteria agreed between COWI and the client. One of the bids is rejected because it is not delivered within the time of delivery (one hour late). After the municipality receives COWI's evaluation, the officer in charge in the municipality contacts COWI's project manager requesting him to revise the evaluation note and to include the rejected bidder into the note. The rejected bidder has the contract for the present work and is a local contractor. Should COWI revise the evaluation as requested No, COWI shall refuse the request with reference to the formal requirements governing tendering. Dilemma1 Q&A Dilemma 2 The officer in charge in the municipality approaches COWI's project manager again proposing to include the rejected bid in the evaluation note with reference to: A copy of the bid was found in the town hall and this copy was delivered within the time of delivery. Does, this make any difference? Q&A D:\Docstoc\Working\pdf\83e51556-90c7-4fa4-8d49-a04ec422b2d1.doc Business Integrity, Cases and Dilemmas 11 / 14 No, COWI must maintains its evaluation, but could at the same time emphasise that the municipality has the right to deviate from our nomination, but they then must accept the full responsibility for a possible appeal. Dilemma 3 One day later the officer in charge phones COWI's project manager urging him to revise the evaluation note by including the rejected bid with reference to his job and COWI's possibilities for future jobs for the municipality. Does this make any difference? No, COWI must strictly adhere to agreed rules for tendering despite the threats for loosing future jobs. Q&A Scenario 3.12 Speed up Customs Clearance In a country in Africa a project office is being mobilised. In order to meet the deadlines of the project, IT equipment needs to be imported from abroad. After one week the equipment arrives at the airport. There is no clearance duty on IT equipment. The project manager is told that the normal customs clearance of such equipment is up to six weeks, but if he pays 50 US$ cash, clearance of the IT equipment can be reduced to three days. Is it acceptable to pay the 50 US$ in order to get clearance of the goods within three days? Such payment, which often is named facilitation payment, should always be avoided. However, in this case where the clearance of the IT equipment is a routine action is it acceptable to pay 50 US$ to expedite customs clearance in order to prevent postponement of actual start up of the project by say one month. Q&A Modified scenario The equipment arrives at the airport and the clearance takes only a couple of days. However, customs duty on new IT equipment is 50%, but the official tells the project manager that it is possible to reduce the duty to 5% by paying cash. Should the project manager accept this offer? No, this is bribery and is not acceptable. The project manager is paying an official a small amount of money with the purpose to avoid the official in performing his duty. Q&A Scenario 3.13 Giving a gift to a client A key person with one of our public clients is celebrating his fiftieth birthday, and a reception is announced in the newspaper. COWI have some ongoing projects and has recently filed a bid for a major future job. A COWI representative personally hands over six bottles of wine to the person at the reception. Is it acceptable to give this present under the given circumstances? Q&A D:\Docstoc\Working\pdf\83e51556-90c7-4fa4-8d49-a04ec422b2d1.doc Business Integrity, Cases and Dilemmas 12 / 14 Six bottles of wine to a fiftieth birthday is within normal business relations and is fully acceptable even under the present conditions. Modified scenario The COWI representative knows that the person does not drink wine and that he will not have the time to participate in the reception. He decides to send a gift certificate to a furniture store at a value of 1000 DKK. Is it acceptable to give the person a gift certificate of 1000 DKK? In general it is not acceptable to give a gift certificate in business relations. A gift certificate is very close to cool cash and cash should never be given as a gift to confirm a business relation. Q&A Scenario 3.14 Sub-consultant nominated by the client COWI has signed a contract with an Executing Agency for a project funded through an International Donor Agency, and is about to start the services. The TOR and the contract Conditions identifies a Nominated Sub-consultant (local company) for collection of data needed for execution of the services. Payment for the said services is fixed. After kick-off and during the inception phase it becomes clear that the Subconsultant has very close (family) relations with the Director of the executing agency. It also becomes clear that the Sub-consultant does not intend to or does not have the ability to collect the data. It is not a crime to have family members or friends among the stakeholders around the project. But from COWI's stakeholder analysis it is evident that getting rid of the Sub-consultant would result in major time consuming (and thereby costly) and delicate discussions with the Executing Agency, who could also put up very unpleasant obstructions for COWI's work. Collection of the needed data by COWI's own staff will have some cost implications. Q &A Is it acceptable to pay the Sub-consultant for work he does not perform? A commercial evaluation of the situation could reveal that it would be less costly to pay the Sub-consultant for work not performed. However, from a business integrity point of view such behaviour could be considered direct or indirect payment of a bribe to the Director of Executing Agency due to his close family relations with the Sub-consultant. Consequently it is not acceptable to pay the Sub-consultant for work not performed by him. The problem is to be discussed with the Business Unit Manager with the purpose to decide the cause of actions, which for example could be:  Disclose the problem to the International Donor Agency and discuss possible actions D:\Docstoc\Working\pdf\83e51556-90c7-4fa4-8d49-a04ec422b2d1.doc Business Integrity, Cases and Dilemmas 13 / 14   Meet with the Executing Agency with agreed minutes of meeting redefining the scope of services for the Sub-consultant to some flexible logistic support services for the same fixed fee. Signed minutes of meeting sent to the International Donor Agency for endorsement ("No objection") to the change, i.e. full transparency, and we pay (a little too much!!) for services performed. Scenario Entertainment/benefits offered by a supplier of computer software A main supplier of computer hardware and software invites its ten most important customers to participate in a one day trip to see the Formula 1 race at the Monza Racing Court. It is a personal invitation to the person who has the contact with the supplier. Is it acceptable to participate in this arrangement? The question is if an arrangement of this kind is within the normal business practice or the expenses for the trip are beyond any reasonable amount. The costs of such a trip are in a magnitude that we should refuse to participate. Participation should only be acceptable under very special conditions, e.g. we have had a long business relationship with the supplier and have recently concluded/extended a major frame agreement with the supplier. 3.15 Q&A Q&A Does it matter if the invitation is to the company and not to an individual? Yes it does. An open invitation to the company is more acceptable than an invitation to a named individual. However, in this case the costs are at such a level that in this particular case it wouldn't make any difference. Q&A Does it matter if COWI within two weeks shall decide on prolongation of the frame agreement with the supplier? Yes it does. We should not participate under these circumstances. Any sort of entertainment invited to by a supplier, COWI are negotiating with, should be refused. Q&A Does it matter if the trip is extended with one day in order to participate in a presentation on the current developments in IT? If the main purpose of the trip is still entertainment, there should be no change in how to act. However, if the main purpose of the trip is changed from entertainment to business, the conditions change a bit. But only one day's extension with relevant technical issues does not change the decision. The situation is quite different if COWI is to participate in an IT conference in Milan for one week and, as a conclusion of the conference, one of our main IT suppliers invite COWI together with its nine other most important customers to watch the Formula 1 race. This is considered to be acceptable. One should bear in mind that in addition to getting new knowledge from business related presen- D:\Docstoc\Working\pdf\83e51556-90c7-4fa4-8d49-a04ec422b2d1.doc Business Integrity, Cases and Dilemmas 14 / 14 tations, it is also business relevant to participate in events where valuable network relations can be established. D:\Docstoc\Working\pdf\83e51556-90c7-4fa4-8d49-a04ec422b2d1.doc