This sample provision illustrates how to incorporate a necessary element of a comprehensive FCPA program into your company’s compliance library and is designed to help compliance professionals ensure they have considered all of the issues. Certification language for a policy provision covering facilitating payments must clearly state employees’ responsibilities in dealing with so-called grease payments.
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The information in any resource collected in this virtual library should not be construed as legal advice or legal opinion on specific facts and should not be considered representative of the views of its authors, its sponsors, and/or ACC. These resources are not intended as a definitive statement on the subject addressed. Rather, they are intended to serve as a tool providing practical advice and references for the busy in-house practitioner and other readers.
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