This overview provides a brief roadmap of the important elements of a comprehensive program to comply with the US Foreign Corrupt Practices Act (FCPA), and is designed to help compliance professionals ensure they have considered all of the issues. A strong compliance program incorporates several core functions and ensures that a company is protecting itself as much as possible against FCPA violations and liability.
This Check Card provides a handy reminder of key elements of your company’s Foreign Corrupt Practices Act (FCPA) compliance policy and is designed to help employees ensure they make a habit of considering all potential corruption issues. The do's and don’ts covering the company’s FCPA policy must provide clear expectations for engaging in conduct with business partners and other third parties.
This sample checklist illustrates how to implement a necessary element of a comprehensive Foreign Corrupt Practices Act (FCPA) program, and is designed to help compliance professionals, in the United States, ensure they have considered all of the issues. Thorough and well-documented due diligence on third parties is a crucial element in a company’s compliance program to prevent liability under the FCPA.
This sample CEO message illustrates how to incorporate an important element of a comprehensive FCPA program into your company’s compliance plan and is designed to help compliance professionals ensure they have considered all of the issues. Senior management should send a strong message that the company is unequivocally committed to ethical behavior and compliance.
This sample certification language 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 employee compliance must clearly state employees’ responsibilities in agreeing to not engage in, and to report, corrupt conduct.
This sample request form 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. To avoid violating the FCPA, companies must take care not to give anything of value, including entertainment, to foreign government officials.
This sample filing language 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. Disclosure language covering FCPA risks must clearly state that the company is aware of corruption risks and has implemented specific compliance efforts.
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 third-party compliance must clearly state parties’ responsibilities in agreeing to not engage in corrupt conduct.
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. Joint venture conduct policies must clearly state expectations that all partners agree to implement and maintain anti-bribery and anti-corruption controls.
This sample filing illustrates how to implement 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. Disclosure language for SEC filings must clearly state the circumstances surrounding an investigation into alleged violations of the FCPA as well as address cooperation and compliance controls.