What Should a Very Progressive Ethics Code Cover?
Note: Links to our free templates are at the bottom of this long guide.
Also note: This is not legal advice
Introduction
Ethics codes are an integral part of any successful organization, providing employees with a framework to work within and promoting a corporate culture that values integrity and ethical behavior. At ¶¶Ňő¶ĚĘÓƵ, we understand the importance of having an effective code in place; the ¶¶Ňő¶ĚĘÓƵ team have seen firsthand how critical it is for organizations to have an ethics code that is tailored to their unique needs.
An ethics code helps to ensure that everyone is clear on what is and isn’t acceptable, helping to prevent workplace misconduct and hold employees accountable if they fail to meet the standards set out by the organization. By demonstrating commitment to ethical behavior, organizations can send a message of trustworthiness and competence – reassuring customers, shareholders, and other external stakeholders that their interests are taken seriously. Furthermore, having a framework in place will also help protect organizations from potential legal issues related to employee conduct.
Creating an effective ethics code isn’t easy - consensus on what should be included can vary widely depending on the industry or type of business - but it’s worth investing in drafting one that meets your organization’s specific needs. To make this process easier, ¶¶Ňő¶ĚĘÓƵ offers free access to its template library containing millions of datapoints – providing guidance on what a market-standard ethics policy looks like without needing legal expertise or paying expensive lawyer fees.
In conclusion, having an effective ethics code in place is essential for any organization looking for success. It provides clarity for employees about expectations of behaviour while showing stakeholders you care about protecting their interests too; ultimately leading not just towards better compliance but improved morale through increased trust between colleagues at all levels. To support those who wish to create high quality legal documents quickly without using lawyers or incurring additional costs our inclusive community template library contains all you need - read on below for our step-by-step guidance so you can find the right approach today!
Definitions
Ethics Code - A set of rules and guidelines designed to ensure that everyone in an organization behaves ethically and follows the same standards of conduct.
Legal Requirements - Laws and regulations that must be followed in order to create an effective ethics code.
Jurisdiction - The set of laws or regulations that apply to a particular area or organization.
Industry Standards - Accepted practices in a particular industry that should be taken into consideration when creating an ethics code.
Ethical Risks - Potential risks to an organization that arise from unethical behavior.
Stakeholders - People, groups, or organizations that have a vested interest in the success of a company.
Accountability - Being answerable for one’s actions.
Transparency - Openness and honesty in communication.
Disciplinary Steps - Actions taken as a result of an ethical violation, such as verbal warnings or dismissal.
Contents
- Defining the purpose of the ethics code and setting expectations
- Clarifying the types of ethical practices that are expected of employees
- Explaining why the code is necessary and what it hopes to achieve
- Understanding the legal requirements and implications of the code
- Investigating relevant laws and regulations that may affect the code
- Researching any industry standards that should be taken into consideration
- Identifying ethical considerations and practices
- Analyzing the potential ethical risks of the organization
- Exploring the ethical implications of the organization’s activities
- Creating a comprehensive code that covers all necessary areas
- Identifying the topics to be included in the code
- Outlining the expectations of employees in each category
- Establishing a process for ongoing evaluation and updates
- Determining how often the code should be assessed
- Defining the criteria for when an update is necessary
- Creating a system to ensure compliance with the code
- Establishing a system of accountability for employees
- Developing a process for monitoring compliance
- Ensuring that all employees are aware of the code and its implications
- Creating training materials to educate employees
- Establishing a system for communicating updates to the code
- Creating a culture of accountability and transparency
- Developing systems to encourage honest communication
- Promoting a culture of open dialogue and trust
- Developing a process to handle potential ethical violations
- Establishing a system to investigate potential violations
- Outlining the disciplinary steps that may be taken
- Establishing a support system for employees who wish to report violations
- Designing a system to protect employees who make reports
- Specifying the resources and support that will be available
Get started
Defining the purpose of the ethics code and setting expectations
- Define the purpose of the ethics code and its importance to the organization
- Establish the expectations for ethical conduct of employees
- Communicate the expectations to employees through training and reminders
- Set up enforcement procedures for violations
- Establish a process for reviewing and updating the code as needed
- Include the ethics code in any employee handbooks and contracts
- Have employees sign an acknowledgment indicating they have read and understand the ethics code
- Check off this step when all of the above have been completed and communicated to employees.
Clarifying the types of ethical practices that are expected of employees
- Review the existing policies and procedures related to ethical practices
- Brainstorm potential ethical practices that could be added to the code
- Create a list of ethical practices that should be included in the code
- Make sure the list is comprehensive, covering all areas of potential ethical issues
- Make sure the list is clear and understandable
- Make sure the list is tailored to the specific organization and its needs
- When the list is complete, move on to the next step: Explaining why the code is necessary and what it hopes to achieve.
Explaining why the code is necessary and what it hopes to achieve
- Research the ethical and legal requirements of the industry
- Outline the purpose of the code and the desired outcomes
- Compile a list of ethical practices and behaviors that the code aims to uphold
- Review the code with legal counsel to ensure that all legal requirements are met
- Craft a narrative explaining why the code is necessary and what it hopes to achieve
- Meet with stakeholders to discuss and explain the code
- Finalize the code and make sure it meets stakeholder expectations
When you have finished this step, you will have a clear narrative and list of ethical practices that the code seeks to uphold. You will also have reviewed the code with legal counsel to ensure that all legal requirements are met.
Understanding the legal requirements and implications of the code
- Research relevant laws, regulations, and legal rulings that may affect the code
- Become familiar with relevant court cases, and pay attention to the outcome of each
- Speak with a lawyer or legal counsel to ensure that the code is compliant with laws and regulations
- Consider the potential risks associated with certain elements of the code
- Analyze the implications of the code in terms of legal rights and responsibilities
- When you are satisfied that you have a full understanding of the legal requirements and implications of the code, move on to the next step.
Investigating relevant laws and regulations that may affect the code
- Analyze any existing state and federal laws that may impact the code, such as labor and anti-discrimination laws
- Familiarize yourself with applicable regulations, such as those related to environmental protection, health and safety, and labor
- Research any industry standards that could be relevant to the code, such as codes of ethics in the industry
- Contact any relevant government and industry organizations to find out more about the laws and regulations that apply to the code
- Take note of any changes to laws and regulations that may affect the code
How you’ll know when you can check this off your list and move on to the next step: When you have a thorough understanding of the laws, regulations, and industry standards that could impact the code and have taken note of any changes, you can move on to the next step.
Researching any industry standards that should be taken into consideration
• Research relevant industry standards and best practices.
• Look into any existing codes of ethics adopted by other organizations in the same field.
• Use this research to inform your own ideas and decisions about what should be included in the ethics code.
• Make sure the code takes into account any industry standards and best practices that could affect the organization.
• When you feel you have a clear understanding of the relevant industry standards, you can move on to the next step.
Identifying ethical considerations and practices
- Define ethical considerations and practices that should be included in the progressive ethics code
- Brainstorm what ethical considerations and practices should be included in the progressive ethics code
- Research relevant legal and regulatory requirements that should be addressed in the progressive ethics code
- Identify any specific ethical considerations and practices that may be unique to the organization
- Ask questions of key stakeholders and other subject matter experts to gain insight into ethical considerations and practices to include in the progressive ethics code
- When you have identified the ethical considerations and practices to include in the progressive ethics code, you can check this step off your list and move on to the next step.
Analyzing the potential ethical risks of the organization
- Research the ethical risks within the organization’s industry, including any applicable laws and regulations
- Identify any potential ethical risks that could arise from the organization’s activities, products, services, or employees
- Identify any potential ethical risks posed by external stakeholders such as suppliers, customers, or competitors
- Consider how the organization’s current and proposed policies and procedures may contribute to or reduce potential ethical risks
- Analyze how potential ethical risks may affect the organization’s reputation or bottom line
- Develop strategies to mitigate any potential ethical risks
You can check this step off your list when you have researched the potential ethical risks of the organization, identified any potential ethical risks, and developed strategies to mitigate those risks.
Exploring the ethical implications of the organization’s activities
- Identify the ethical implications of the organization’s activities, such as the impact on stakeholders and the environment
- Assess the organization’s current policies and practices to determine whether they are in line with ethical standards
- Consult with stakeholders to gain insights into the ethical implications of the organization’s activities
- Research current ethical standards, such as those set by professional organizations, and determine their applicability to the organization’s activities
- Analyze the ethical implications of the organization’s activities and develop recommendations for improvement
How you’ll know when you can check this off your list and move on to the next step:
- When you have identified the ethical implications of the organization’s activities, assessed their current policies and practices, consulted with stakeholders, researched current standards, and analyzed the ethical implications to develop recommendations for improvement.
Creating a comprehensive code that covers all necessary areas
- Identify the areas of ethical decision-making that need to be addressed in the code
- Identify the ethical principles that are relevant to the organization
- Draft the code of ethics, making sure to include all necessary areas
- Ensure the code covers both internal and external ethical responsibilities
- Have the code reviewed and approved by key stakeholders
- Publish the code of ethics for all employees to review
- Establish an enforcement mechanism for any violations of the code
How you’ll know when you can check this off your list and move on to the next step:
Once the code of ethics has been drafted, reviewed, and approved, and published for all employees to review, this step can be checked off the list and the next step can begin.
Identifying the topics to be included in the code
- Research current codes of ethics, as well as legal and compliance requirements
- Identify any additional topics to be included in the code
- Make sure the topics are clearly defined and relevant
- Consider topics such as corporate responsibility, sustainability, diversity, safety, and conflict of interest
- Take into account the company’s values and mission statement
- When complete, review the list of topics to make sure they are comprehensive and relevant
- When finished, you will have a complete list of topics and standards to include in the code.
Outlining the expectations of employees in each category
- Identify the actions and attitudes that you expect from your employees.
- Clearly explain the consequences of violating the code.
- Create a plan for how you’ll communicate expectations to employees.
- Determine how you will ensure that employees understand the code.
- Create a system for documenting any violations of the code and the resulting consequences.
- Establish a process to update the code as needed.
How you’ll know when you can check this off your list and move on to the next step:
- When you have identified the actions and attitudes you expect your employees to follow, clearly outlined the consequences for violations, created a plan for communication, determined how to ensure understanding of the code, documented violations and their consequences, and established a process to update the code as needed, you can move on to the next step.
Establishing a process for ongoing evaluation and updates
- Designate a team or individual to review the ethics code periodically.
- Define the review process and timeline.
- Set expectations for how the code should be updated and when.
- Consider asking for employee feedback on the code.
- Determine a method for disseminating information about the code to employees.
- Establish a plan for keeping the code current.
Once you have a review team in place, a review process in place, and expectations for when and how the code should be updated, you can check this step off your list and move onto the next step.
Determining how often the code should be assessed
- Decide on a timeline for assessing the code. This should be a reasonable time frame that allows the code to be reviewed and updated regularly.
- Consider factors such as the rate of change in the industry, the company’s growth rate, and how often new technology may be introduced.
- Establish a process for regularly assessing the ethics code that is clearly documented and communicated to stakeholders.
- Consider using a committee or task force of stakeholders to review the code every so often.
- When the code is reviewed, decide whether or not it needs to be updated.
- Once you have established the timeline and process, document it in the code and communicate it to stakeholders.
- When the timeline and process are documented and communicated, you can check this off your list and move on to the next step.
Defining the criteria for when an update is necessary
- Brainstorm a list of potential criteria that could signal the need for an update
- Consider factors such as changes in the workplace, changes in laws, changes in the industry, changes in customer/client needs, changes in the values of the organization, and changes in the public’s perception of the organization
- Identify which current processes, procedures, and policies are most likely to require updates
- Assess the resources available for updating the ethics code
- Develop a set of criteria for determining when an update is necessary
- Check off the step when the criteria for when an update is necessary has been defined and documented.
Creating a system to ensure compliance with the code
- Develop a system to ensure employees comply with the ethics code.
- Create an internal compliance system that includes policies, procedures, and protocols that ensure adherence to the ethics code.
- Establish an internal team to oversee compliance and answer questions or provide guidance on ethical issues.
- Establish a system of reporting and investigating any potential violations of the code.
- Establish a system of rewards and sanctions for employees who adhere to or violate the code.
- When the system is adequate and in place, check this off your list and move on to the next step.
Establishing a system of accountability for employees
- Establish a system of accountability for employees, such as a system of penalties for unethical behavior and rewards for ethical behavior.
- Consider both positive and negative reinforcement measures, such as rewards for ethical behavior and punishments for unethical behavior.
- Develop and implement a system to ensure that employees are held accountable for their actions.
- Establish and communicate clear consequences for unethical behavior.
- Establish a process for regularly monitoring employees to ensure that they are following the code of ethics.
- When you have established a system of accountability for employees, you can check this off your list and move on to the next step.
Developing a process for monitoring compliance
- Create a system for regularly monitoring employee conduct
- Develop a process for reporting any compliance issues and ensure that all employees are aware of the reporting process
- Establish a system for investigating reported issues and enforcing compliance with the ethics code
- Develop a system for rewarding exemplary behavior and punishing unethical behavior
- Ensure that all employees receive regular training on the ethics code
- Check that all employees are fully aware of their responsibilities as outlined by the ethics code
- When you are confident that you have a well-defined and regularly monitored process in place, you can check this off your list and move on to the next step.
Ensuring that all employees are aware of the code and its implications
- Design a way to distribute the ethics code to all employees, such as emailing it to each employee or posting it on the intranet
- Develop a clear timeline for when employees must read and understand the code
- Create a way for employees to ask questions about the code, such as an internal help desk or chatbot
- Develop a system for tracking which employees have read and understood the code, such as having them sign a form
- Once the above steps are completed and employees are aware of the code and its implications, this step can be checked off and you can move on to the next step.
Creating training materials to educate employees
- Determine the most appropriate way to deliver the training materials, such as an online course, in-person seminar, or a combination of both.
- Create a training program with the goal of making sure all employees understand the code, its implications, and their responsibilities.
- Include a quiz or assessment at the end of the training to ensure employees have retained the material.
- Once the training program is complete, review it with a sample group of employees to make sure they understand the material and that the training is effective.
- Make sure the training materials are accessible to all employees.
- When the training is complete and all employees have been trained, mark this step as complete and move on to the next step.
Establishing a system for communicating updates to the code
- Develop a plan for how the code updates will be communicated to the organization
- Determine the appropriate channels for communicating (e.g. email, internal newsletters, etc.)
- Establish a timeline for when updates will be communicated
- Identify who will be responsible for communicating the updates
- Decide how often the code will need to be reviewed and updated
- When the code is updated, communicate any changes and the reasons for them
- When communicating, ensure that employees understand the importance of the code and the need to adhere to it
When you can check this off your list and move on to the next step:
- When a plan and timeline for communication is established
- When the channels of communication have been determined
- When the responsibility for communicating the updates is assigned
- When the frequency of reviews and updates are established
- When the code has been communicated and employees understand the importance of adhering to it.
Creating a culture of accountability and transparency
- Establish clear objectives and goals for the code of ethics
- Identify any potential conflicts of interest and develop a plan for managing them
- Develop a system for reporting and responding to ethical violations
- Define processes for holding individuals and teams accountable for adhering to the code of ethics
- Create a system for communicating updates to the code of ethics to employees, vendors, and other stakeholders
- Develop clear guidelines for any disciplinary or corrective action related to ethical violations
- Foster an environment of transparency and open communication by providing employees with an understanding of the code of ethics and its purpose
- Encourage employees to ask questions and provide feedback on the code of ethics
How you’ll know when you can check this off your list and move on to the next step:
- When the code of ethics is established, with clear objectives and goals, a system for reporting and responding to ethical violations, and processes for holding individuals and teams accountable, you can move on to the next step.
Developing systems to encourage honest communication
- Analyze existing communication policies and practices
- Identify areas of improvement in terms of communication
- Develop strategies to encourage honest communication in the workplace
- Introduce systems to reward honest communication
- Establish an anonymous reporting system
- Ensure confidentiality when discussing sensitive topics
- Provide training on communication protocols and etiquette
- Make sure that employees feel comfortable voicing their opinions
- Establish a feedback loop to assess the effectiveness of communication systems
Once you have developed systems to encourage honest communication and implemented them in the workplace, you can move on to the next step of promoting a culture of open dialogue and trust.
Promoting a culture of open dialogue and trust
- Establish a culture of open dialogue and trust between management and employees.
- Encourage honest feedback and conversations by setting a positive example.
- Create a safe environment where employees can express their opinions without fear of retribution.
- Make sure that everyone is aware of the expectations of ethical behavior and ensure that employees understand their rights and responsibilities.
- Ensure that employees are comfortable raising issues and concerns without fear of retribution.
- Foster an environment of mutual respect and understanding, and allow employees to report any potential ethical violations without fear of retaliation.
How you’ll know when you can check this off your list and move on to the next step:
- When employees are comfortable expressing their opinions, raising issues and concerns, and reporting potential ethical violations without fear of retaliation.
- When you have established a culture of open dialogue and trust between management and employees.
- When you have established a safe environment where employees can express their opinions without fear of retribution.
- When everyone is aware of the expectations of ethical behavior and understand their rights and responsibilities.
Developing a process to handle potential ethical violations
- Establish a clear process to identify and address potential ethical violations.
- Create a set of guidelines that specify when a situation should be reported, who is responsible for reporting it, and what the process and timeline for addressing the situation looks like.
- Make sure all staff, volunteers, and board members are aware of the process, and how to report an ethical violation.
- Consider setting up a confidential hotline for anonymous reporting.
- Develop an action plan for how the organization will respond to an ethical violation.
- Create an internal process to review and investigate any reports of ethical violations.
- Once the investigation has been completed, determine the most appropriate response to the violation.
- Document the process and any actions taken, and ensure that all parties involved are aware of the outcome.
How you’ll know when you can check this off your list and move on to the next step:
You will know this step is complete once the organization has developed a clear process for reporting potential ethical violations, established guidelines for when a violation should be reported, and created an action plan for responding to the violation.
Establishing a system to investigate potential violations
- Establish a comprehensive system for identifying potential ethical violations
- Ensure that the system is transparent and accountable to all stakeholders
- Appoint an investigative body/committee to assess any potential violations and make recommendations
- Make sure the investigative body/committee is composed of members from diverse backgrounds and perspectives
- Define the scope of the investigative body/committee and how it will interact with other stakeholders
- Establish a timeline and processes to ensure that investigations are conducted in a timely manner
- When the investigation is complete, the investigative body/committee should make recommendations on how to address the violation
- Once recommendations are made, they should be reviewed and approved by the appropriate authority
- Check off this step and move on to the next step once the system is established and operational.
Outlining the disciplinary steps that may be taken
- Establish a clear list of disciplinary steps that can be taken if an employee is found to have violated the ethics code, such as verbal warning, written warning, suspension, and termination
- Make sure the list is detailed enough so that all employees are aware of the consequences of violating the ethics code
- If possible, specify the exact circumstances in which each disciplinary action is appropriate
- Ensure that the list of disciplinary steps is compliant with any applicable local, state, and federal laws
- Make sure the list is consistently applied across all departments and all employees
- Once the disciplinary steps are established, you should review and update the list as needed
- You can check this off your list and move on to the next step once the disciplinary steps have been outlined and approved by the appropriate authorities.
Establishing a support system for employees who wish to report violations
- Create a system of contact points who will be available to receive and address reports of ethical violations.
- Make sure this system is clearly outlined in the code of ethics.
- Ensure that any employee who wishes to report a violation can contact these contact points without fear of retribution.
- Establish a system for protecting the identity of the employee who reports any violations.
- Outline the process for how reports will be handled, from the initial contact to resolution.
Once the system for reporting violations and protecting those who report them has been established and outlined in the code of ethics, you can move on to the next step.
Designing a system to protect employees who make reports
- Establish a system for employees to make reports that is easy to understand and use.
- Ensure that employees who make reports will be protected from retaliation.
- Detail the steps that will be taken to investigate any reports.
- Specify the types of sanctions that will be applied if violations are confirmed.
- Make sure that the system is transparent to employees.
- Ensure that the system is regularly reviewed and updated to reflect any changes in policy.
How you’ll know when you can check this off your list and move on to the next step:
- When the system has been designed, tested and implemented.
- When employees have been adequately trained on how to use the system.
- When the system is functioning properly and there is evidence of compliance with the system.
Specifying the resources and support that will be available
- Establish a clear process for how employees can report unethical behavior
- Create a system to track reports, investigate and follow-up
- Provide resources to support employees who make reports, such as counseling and legal services
- Outline the consequences for unethical behavior
- Create an anonymous reporting system
- Establish guidelines on how to handle any retaliation
- Establish a timeline for how quickly the team will investigate allegations
- Create a system to ensure confidentiality
- Determine the best way to communicate the results of investigations
Once you have outlined the resources and support that will be available to employees who make reports, you can check this off your list and move on to the next step.
FAQ
Q: What about jurisdictions outside of the European Union?
Asked by Robert on February 6, 2022.
A: While the European Union has a number of progressive ethics codes and regulations, it is important to note that there are other jurisdictions outside of the EU which may have different or even more progressive ethics codes. Depending on your industry sector or business model, you may need to consider the ethics codes of other countries in order to ensure compliance with local laws and regulations. It’s important to research and understand the ethics codes of any jurisdiction in which you do business or have operations, and ensure that you are compliant with those regulations.
Q: How do I make sure I am compliant with local laws?
Asked by Mary on April 15, 2022.
A: Making sure that you are compliant with local laws is an important step when creating an ethics code for your business. It is important to research and understand the relevant laws and regulations in any jurisdiction in which you wish to operate, and ensure that any ethics code you create will meet those requirements. Additionally, it is important to consult with legal professionals in order to verify that any code you create will be compliant with local laws.
Q: What should be included in a very progressive ethics code?
Asked by David on June 3, 2022.
A: A very progressive ethics code should include a variety of topics such as data privacy, employee rights, anti-discrimination policies, environmental protection policies, and anti-corruption measures. Additionally, it should also include measures which promote ethical behaviour and decision making such as conflict of interest clauses and whistleblowing policies. It is also important to ensure that any code you create is tailored to meet the specific needs of your business or industry sector.
Q: How can I ensure my company follows ethical practices?
Asked by Jennifer on July 21, 2022.
A: Ensuring that your company follows ethical practices is an important step when creating an ethics code for your business. It is important to establish a clear policy for how employees should behave and interact with each other, and what type of behaviour is unacceptable. This should include guidelines for how conflicts of interest should be handled, as well as clear guidelines for how decisions are made and how employees interact with customers or vendors. Additionally, it is important to ensure that any code you create provides effective enforcement mechanisms in order to ensure compliance with the code.
Q: What other areas might a progressive ethics code cover?
Asked by John on August 4, 2022.
A: A progressive ethics code may also cover areas such as corporate social responsibility (CSR), supply chain management practices, corporate governance practices, sustainability initiatives, and transparency initiatives. Additionally, it may also include measures which promote ethical behaviour such as whistleblower protection policies and anti-corruption measures. It is important to ensure that any code you create is tailored to meet the specific needs of your business or industry sector in order to ensure compliance with all applicable laws and regulations.
Q: Are there any best practices when creating an ethics code?
Asked by Sarah on September 21, 2022.
A: When creating an ethics code for your business, it is important to follow best practices in order to ensure compliance with all applicable laws and regulations. This includes researching relevant laws and regulations in any jurisdiction in which you wish to operate; consulting with legal professionals; establishing clear policies for how employees should behave; establishing effective enforcement mechanisms; promoting ethical behaviour; ensuring transparency; and ensuring corporate social responsibility (CSR). Additionally, it is important to tailor any code you create to meet the specific needs of your business or industry sector in order to ensure compliance with all applicable regulations.
Q: Are there any risks associated with having an overly progressive ethics code?
Asked by Michael on October 6th 2022.
A: While having an overly progressive ethics code may provide additional protections for employees or customers, there may be some risks associated with having an overly progressive code which could lead to legal action or other negative consequences if not properly enforced or managed correctly. It is important to consult with legal professionals before creating any type of ethics code in order to ensure compliance with all applicable laws and regulations. Additionally, it is important to tailor any code you create to meet the specific needs of your business or industry sector in order to avoid potential legal risk or other consequences associated with having an overly progressive ethics code.
Example dispute
Suing Companies for Breach of Ethics Code
- A plaintiff might raise a lawsuit against a company if they feel the company has violated their ethical code.
- The plaintiff must provide evidence of the violation of the ethical code, such as documents, testimony, contracts, or emails.
- The plaintiff must show that the company is liable for any damages that resulted from the violation.
- These damages may include financial losses, physical or emotional harm, or reputational harm.
- The plaintiff can reference the company’s own ethical code as evidence of the violation and potential damages.
- Settlement and/or damages can be negotiated between the plaintiff and the company.
- If the plaintiff is successful in proving their case, they may win the suit and receive compensation for any damages.
Templates available (free to use)
Ethics Policy
Statement Of Ethics Boilerplate Bribery Act 2010
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