Foreign Anti Corruption Quiz

15 Questions | Total Attempts: 459

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Government Quizzes & Trivia

This is a quiz to ensure Healthways colleagues have a practical understanding of the Foreign Anti-Corruption program. It is important that all colleagues avoid improper payments to government officials and fully comprehend our values and legal obligations. Thank you for your cooperation and continued diligence to ensure Healthways remains a world class organization.


Questions and Answers
  • 1. 
    For a payment to be considered improper:
    • A. 

      An actual transfer doesn't have to happen.

    • B. 

      It doesn't have to be offered directly to the government official--it can be offered by another individiual or entity.

    • C. 

      It has to have to have the desired outcome.

    • D. 

      Both A and B

    • E. 

      Both A and C

  • 2. 
    Of those listed below, who is considered to be a government official?
    • A. 

      The son of a physician in a state-owned hospital.

    • B. 

      A person with an with an honerary title

    • C. 

      A member of a school board

    • D. 

      All of the above

    • E. 

      None of the above

  • 3. 
    I have befriended a business contact in Ireland named Jill and I want to take her and her family out to a casual dinner.  Jill is not a government official.  She has with a six year old son named Frank, who currently has a friend over, named Patrick. Patrick's father is a low ranking government official. Is it ok if I include him in our plans?
    • A. 

      Yes, because he is only indirectly related to my company, I am not liable under the Foreign Anti-Corruption Policy.

    • B. 

      Yes, if I spend less than $50 on Patrick, or I get express written approval from our CCO for the occasion.

    • C. 

      No.

  • 4. 
    WidgetHealthCare's (WHC) IT Team in Germany has agreed to supply disease management applications to a company owned by the Ministry of Health in Germany for a new project.  After a delivery date is agreed upon, WHC encounters a delay of several months to work out some bugs in the applications.Company officials have asked the IT Team to request that WidgetHeatlhCare host a two-day meeting in the US, with side trips to Las Vegas and Disney World for themselves and some of their family members.  The company officials have stated that they would take care of their own airfare and hotel for the two day meeting.  There is a significantly closer WidgetHealthCare facility in the UK, where the disease management applications are being worked on.  The company officials have indicated that they would consider refraining from imposing on the dealer any damage penalties or cliams under the contract triggered by the delivery days if their request can be accomadated.  Should WidgetHealthcare accomodate their request?
    • A. 

      Yes.

    • B. 

      No.

    • C. 

      Maybe.

  • 5. 
    Mrs. Kang is a potential business partner from Korea.  She works for company XYZ that has no ties to any government agency.  Can I assume that she is not a govenment official?
    • A. 

      Yes

    • B. 

      No

  • 6. 
    Jill is entertaining a government official from Brazil after a long day of meetings.  Jill and the  govenrment official went to an enjoyable dinner and government official suggests that they rent a horse and carraige downtown Nashville for the evening to sight-see.  Jill says this is a fun and reasonable idea, and pays the carraige driver $55 for the fare. Was this act permissable by the Healthways Foreign Corruption Program Policy?
    • A. 

      Yes.

    • B. 

      No.

  • 7. 
    When dealing with any person who may be a foreign official, which of the following conducts may be considered inherently suspicious?
    • A. 

      Requests for meals or charitable contributions

    • B. 

      Requests for alcohol or the hiring of relatives

    • C. 

      Requests for expensive gifts

    • D. 

      B and C

    • E. 

      All of the above

  • 8. 
    Colleagues must promptly report concerns in the manner described above if they become aware of any of the following
    • A. 

      A governmental inquiry, investigation, or subpoena related to any alleged corruption or illegal activity by Healthways, a Director, a Colleague, a Foreign Third-Party Agent or any foreign official with whom any of the foregoing have dealings

    • B. 

      A news report or report from any other source of alleged corruption activity by Healthways, a Colleague, a Healthways shareholder, a Foreign Third-Party Agent, a Healthways client or client representative, or any foreign official with whom Healthways has contact, provided that such report is related to Healthways

    • C. 

      Any other fact or occurrence that suggests that Healthways, a Director, a Colleague, or a Foreign Third-Party Agent may be exposed to FCPA liability or is violating, or has violated, the Foreign Anti-Corruption Program.

    • D. 

      All of the above.

    • E. 

      None of the above.

  • 9. 
    True or False:  We are not responsible for the actions of our vendors or suppliers.
    • A. 

      True

    • B. 

      False

  • 10. 
    True or False:  Payments to foreign officials that are not directly related to an existing or proposed contract will not expose Healthways to FCPA liability.
    • A. 

      True

    • B. 

      False

  • 11. 
    True or False:  Marketing and promotional expenses to educate employees of foreign companies about Healthways and introduce them with our US personnel are allowed by the FCPA.
    • A. 

      True

    • B. 

      False

  • 12. 
    I have noticed the COO or the COO's close colleagues participating in questionable FCP behavior.  I feel too uncomfortable confonting the COO with this issue.  What do I do?
    • A. 

      Resign immediately.

    • B. 

      Ignore it and wait for someone else to notice the problem

    • C. 

      Confront the COO anyway

    • D. 

      Contact Healthways anonymous hotline

    • E. 

      None of the above

  • 13. 
    True or False: Healthways FCP means I cannot do business with foreign government entities.
    • A. 

      True

    • B. 

      False

  • 14. 
    What should I do if I may have violated the Anti-Corruption Program?
    • A. 

      Resign immediately and contact my attorney

    • B. 

      Try to cover up the problem

    • C. 

      Immediately seek guidance from your superior, the Office of the CCO, or the Hotline.

    • D. 

      All of the above

    • E. 

      None of the above

  • 15. 
    True or False: Only Healthways will be liable for FCPA violations, not the colleagues in its employ.
    • A. 

      True

    • B. 

      False

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