You are the Compliance Officer for a midsize software development company, Software,

Inc. Your company's stock is publically traded on all of the major domestic stock exchanges.

The primary business of your company is to develop and then sell inventory-control software to

large retailers. In the last few years, however, more and more of your business is supplying

software to the various branches of the U.S. Military. The company employs a group of 100

salespeople whose primary duty is to market and sell the company's software exclusively to the

military.

In recent meetings with the supervisor of military sales, you have been told that certain military

procurement officers have asked some salespeople for small gratuities to help "sway" the

procurement officer in the company's favor. For example, one procurement official suggested

that in the absence of any identifiable difference between the company's product and a

competitor's, the choice may come down to which one would come across with tickets to an

upcoming major league baseball game.

You recognize that this sort of behavior is wrong, but you also recognize that these things often

happen in the sales business, and that the salespeople may be tempted to cut corners this way.

This is especially true because the salespeople work on commission---the more software they

sell, the more they get paid.

Accordingly, you have decided to create a "compliance plan" that will effectively prevent this

type of bad conduct by the employees. You recognize that the company can be held criminally

liable for the crimes committed by employees.

Your final exam, then, is to write a compliance plan for the company that will prevent the

problem described above,

and any other problems that are related to the business as detailed

above.

In other words, your compliance plan must address this possible bribery issue, as well as

any other issues that could result in liability for the company.

I recognize that a fully detailed compliance plan can cover dozens of pages. That's not what I'm

looking for on this exam. Rather, I want you to identify 3 or 4 issues that you will address in

your compliance plan (one of them being, of course, the giving of gratuities to obtain business).