Referral Designation Types


The Anti-Corruption review is intended to mitigate the risk associated with hiring referrals from clients, potential clients and government officials. To do this effectively, correct designation of the source of the referral is required.

Definitions are as follows:

Government Official: The origin of the referral is a Government Official (which includes a candidate who is him or herself, a Government Official). Pursuant to the Anti-Corruption Policy, Government Officials includes all officials, employees (regardless of rank or level), or agents of any of the following:

  • U.S. and non-U.S. Government bodies, departments, agencies, instrumentalities, corporates or other political subdivisions of a national, state or local government body. The term is construed broadly and includes employees of public pension funds, public universities and school districts, public hospitals, port and water authorities, and economic development corporations
  • Public international organizations (e.g., The World Bank, International Monetary Fund, United Nations)
  • Political parties or candidates for political office
  • Government-controlled entities (e.g., a sovereign wealth fund or state-owned entity)

For purposes of this Policy an entity is deemed to be government-controlled if any government, either directly or indirectly (e.g., subsidiaries) has one of the following:

  • 50% or more ownership
  • Voting control
  • Board appointing control or Other mechanism of control (e.g., Golden Share)

Supplemental definitions may be found APAC and EMEA supplements to the Anti-Corruption Policy.

If the source of the referral is Client or Potential Client or Personal/Professional and Government Official, please select Government Official.

Client or Potential Client:  The origin of the referral is a client or a potential client (which includes a candidate who is him or herself, a client or potential client).

If the source of the referral is Client or Potential Client and Personal/Professional, please select Client or Potential Client.

If the source of the referral is Client or Potential Client and Government Official, please select Government Official.

Personal/Professional:  The origin of the referral (which includes a candidate, him or herself) is personal (i.e., a friend, relative, and acquaintance), professional (i.e., a business relationship, other than a known client, potential client, or government official) or other type of business-network relationship.

If multiple selections are applicable, select the option based upon the order of importance, with government official having the highest level of importance followed by client or potential client.