The fine line between retailer incentives and commercial bribery
February 12, 2017 | BY
Katherine Jo &clp articlesDLA Piper
Nate Bush & Zhou Yang
In response to China's intensified antitrust and anti-bribery enforcement, many multinational companies (MNCs) have reinforced their China compliance programs by importing global policies and procedures. However, recent enforcement actions targeting retailer incentive programs demonstrate the risk that certain commercial practices viewed as antitrust risks in other jurisdictions may be condemned as commercial bribery in China.
In most jurisdictions, bribery offenses involve improper offers or payments toindividuals to induce or reward them to act contrary to their lawful duties