Read the following article and answer the questions.

BHP Billiton hit with $US25m fine over corruption allegations BHP Billiton has been fined by US regulators over hospitality provided to government officials — including ones from shady foreign governments — during the 2008 Olympic Games in Beijing.

The world’s biggest miner has made no admissions but has agreed to pay $US25 million ($30 million) to settle charges that it violated anti-bribery and corruption laws.

The settlement deal resolves charges by the US Securities and Exchange Commission that BHP violated the Foreign Corrupt Practices Act when it invited officials who were ‘directly involved with, or in a position to influence’ its business and regulatory affairs.

BHP neither admitted nor denied wrongdoing and said the US Department of Justice ended a related criminal probe without taking action.

According to the SEC, BHP invited 176 government officials to attend the Olympics at company expense, including 98 who worked for state-owned enterprises that were customers or suppliers, under a ‘global hospitality’ program tied to its sponsorship of the games.

The 60 officials who finally agreed to attend were mainly from Africa and Asia and enjoyed packages worth up to $US16,000 that included luxury hotels, event tickets and sightseeing tours.

In an example cited by the SEC, BHP invited a provincial governor from the Democratic Republic of the Congo who was thought to be ‘key’ to a copper exploration deal BHP was pursuing. The official accepted but later cancelled. However, the SEC says BHP did not properly monitor the invitation process or train employees to ensure that the program would remain untainted by bribery. ‘BHP Billiton recognized that inviting government officials to the Olympics created a heightened risk of violating anti-corruption laws, yet the company failed to implement sufficient internal controls to address that heightened risk,’ said Andrew Ceresney, director of the SEC enforcement division.

In a statement, BHP said it has taken ‘significant’ remedial steps to upgrade its internal controls. It also said it fully cooperated with the SEC, and will keep cooperating with an Australian Federal Police investigation announced in 2013.

‘Our company has learned from this experience and is better and stronger as a result,’ chief executive officer Andrew Mackenzie said in a statement.

The SEC’s investigation sheds light on BHP’s checks and balances in the lead-up to the Beijing games, especially in dealing with nations known for corruption.

At the time of the Beijing games, when Marius Kloppers was heading the miner, BHP had no internal compliance function in place. Instead business managers completed a form inviting guests without any upward review or approval process.

But the SEC said a ‘check the box’ was not good enough, staff had not received the proper training and some hospitality forms were inaccurate or incomplete.

BHP said it now has better compliance and that the Risk and Audit Committee of the BHP board needs to approve any offer of hospitality to a government official.

The fine comes as regulators around the world — the US, Britain, the European Union — are coming down hard on companies and foreign officials that give and take bribes.

Required

(a) Identify the stakeholders in this situation.

(b) Determine the ethical issues (if any) involved.

(c) Comment on the ethics of bribing officials in a country where you are conducting business given that such actions are part of the country’s normal business practice, but they are unacceptable in your own country.

(d) In other articles discussing these activities, reference has been made to a Global Witness report. Provide a dossier on Global Witness (see www.globalwitness.org/).

(e) Locate the charter of BHP’s Risk and Audit Committee. Summarise the role of this committee.