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Anti Bribery & Anti Corruption Policy Generator for the USA

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Key Requirements PROMPT example:

Anti Bribery & Anti Corruption Policy

"Need an Anti Bribery & Anti Corruption Policy for our technology startup that's expanding into Asia, with specific focus on third-party relationships and gift policies; must be compliant with both U.S. FCPA and local regulations by January 2025."

Document background

The Anti-Bribery & Anti-Corruption Policy is essential for organizations operating in today's global business environment, where regulatory scrutiny of corrupt practices continues to intensify. This policy document is particularly crucial for compliance with U.S. legislation, including the FCPA and state-specific regulations. It should be implemented when organizations need to establish clear guidelines for preventing corruption, managing risk, and maintaining ethical business practices. The policy typically includes provisions for gift-giving, entertainment, facilitation payments, political contributions, and charitable donations, along with detailed reporting and monitoring procedures.

Suggested Sections

1. Purpose and Scope: Defines the policy's objectives and who it applies to within the organization

2. Definitions: Detailed definitions of key terms used throughout the policy including 'bribery', 'corruption', 'public officials', and 'facilitation payments'

3. Policy Statement: Organization's commitment to zero tolerance for bribery and corruption, including compliance with FCPA and other applicable laws

4. Prohibited Conduct: Detailed description of prohibited activities including bribes, kickbacks, facilitation payments, and improper gifts

5. Reporting Procedures: Procedures for reporting violations, whistleblower protections, and investigation protocols

6. Compliance Monitoring: Methods and procedures for monitoring compliance, including audits and internal controls

Optional Sections

1. Purpose and Scope: Defines the policy's objectives and who it applies to within the organization

2. Definitions: Detailed definitions of key terms used throughout the policy including 'bribery', 'corruption', 'public officials', and 'facilitation payments'

3. Policy Statement: Organization's commitment to zero tolerance for bribery and corruption, including compliance with FCPA and other applicable laws

4. Prohibited Conduct: Detailed description of prohibited activities including bribes, kickbacks, facilitation payments, and improper gifts

5. Reporting Procedures: Procedures for reporting violations, whistleblower protections, and investigation protocols

6. Compliance Monitoring: Methods and procedures for monitoring compliance, including audits and internal controls

Suggested Schedules

1. Schedule A - Red Flag Indicators: Comprehensive list of warning signs that may indicate corrupt practices or violations

2. Schedule B - Reporting Forms: Standard templates and forms for reporting violations or concerns

3. Schedule C - Due Diligence Checklists: Standardized forms and procedures for vetting third parties and business partners

4. Schedule D - Gift and Hospitality Register: Template and guidelines for recording gifts, entertainment, and hospitality

5. Schedule E - Training Materials: Reference materials and guidelines for employee anti-corruption training

Authors

Alex Denne

Head of Growth (Open Source Law) @ ¶¶Òõ¶ÌÊÓƵ | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents | Serial Founder & Legal AI Author

Clauses






























Industries

Foreign Corrupt Practices Act (FCPA): Primary U.S. federal law that prohibits the payment of bribes to foreign officials to assist in obtaining or retaining business. Contains anti-bribery provisions, books and records provisions, and internal controls requirements.

Travel Act: Federal law that prohibits travel between states or countries with the intent to promote unlawful activities, including commercial bribery.

State Anti-Corruption Laws: Various state-specific regulations and commercial bribery statutes that may impose additional requirements or restrictions at the state level.

UK Bribery Act: International legislation relevant for U.S. companies with overseas operations. More stringent than FCPA, covering both public and private sector bribery.

OECD Anti-Bribery Convention: International anti-bribery standards and requirements promoting cross-border enforcement cooperation among signatory countries.

Sarbanes-Oxley Act: U.S. federal law establishing enhanced financial reporting requirements and internal controls provisions for public companies.

Dodd-Frank Act: U.S. federal law containing whistleblower provisions and reporting requirements related to corporate governance and transparency.

Anti-Money Laundering Regulations: Including Bank Secrecy Act and USA PATRIOT Act provisions, requiring organizations to implement programs to prevent money laundering and related financial crimes.

Healthcare Anti-Kickback Statute: Industry-specific regulation prohibiting the exchange of anything of value to induce or reward referrals in federal healthcare programs.

Stark Law: Healthcare-specific legislation prohibiting physician self-referral where a financial relationship exists.

Federal Acquisition Regulations: Government contracting rules establishing procurement requirements and anti-corruption provisions for federal contractors.

Procurement Integrity Act: Legislation governing the conduct of federal procurement officials and contractors during the procurement process.

Teams

Employer, Employee, Start Date, Job Title, Department, Location, Probationary Period, Notice Period, Salary, Overtime, Vacation Pay, Statutory Holidays, Benefits, Bonus, Expenses, Working Hours, Rest Breaks,  Leaves of Absence, Confidentiality, Intellectual Property, Non-Solicitation, Non-Competition, Code of Conduct, Termination,  Severance Pay, Governing Law, Entire Agreemen

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