Introduction
What if a Polish subsidiary of a U.S. pharmaceutical company donated approximately US$76,000 to a charitable foundation in Poland? Would you find that honourable?
What if the head of the charitable foundation was also a director at a Polish governmental body that provided money for the purchase of pharmaceutical products and exerted influence over hospitals' pharmaceutical purchases?
Now a potentially noble charitable donation looks much more suspect. This example is based on a real violation of the U.S. Foreign Corrupt Practices Act that resulted in the involved company paying a US$500,000 penalty.
So when are charitable donations allowed?