Company P, a U.S. company, has a foreign subsidiary in Country Q, where various forms of bribery are accepted and expected. Company P sent one of its top U.S. managers to oversee operations in its subsidiary in Country Q. That manager engaged in the following activities while in Country Q:
a. Paid the equivalent of $200,000 to a government official to win the bid for a new manufacturing facility that opened on April 15.
b. Paid about $80 each to four local clerks at the import agency who agreed to move the company’s import inspection process to expedite status, saving the company one week of inspection time.
c. The streets and sanitation department in Country Q is government owned and operated. Because of many hurricanes, downed trees and other debris frequently block access to the roads leading to the plant. The manager paid the official in charge of streets an additional $200 to ensure quick clearing of the streets leading to the plant.
d. After learning that a competing foreign company paid a government official in Country Q $10,000 to have priority consideration on a new contract to supply the military, the manager of Company P offered the official $20,000 for priority consideration for the same contract.
Under the Foreign Corrupt Practices Act as amended, which of the above activities would be considered illegal? From an operations standpoint, which of the above activities would be considered bad management practice? What alternative actions could you suggest for the manager?
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