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Anti Bribery & Corruption Policy Generator for the USA

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Key Requirements PROMPT example:

Anti Bribery & Corruption Policy

"I need a comprehensive Anti Bribery & Corruption Policy for my fintech startup that's expanding into Asian markets in March 2025, with specific focus on digital payments and cryptocurrency transactions, ensuring compliance with both U.S. and Asian regulations."

Document background

The Anti-Bribery & Corruption Policy serves as a critical compliance tool for organizations operating under U.S. jurisdiction. It is designed to ensure compliance with the FCPA, state laws, and international anti-corruption legislation where applicable. This policy becomes essential when organizations engage in international business, interact with government officials, or operate in high-risk markets. It typically includes detailed guidance on risk assessment, due diligence procedures, gift and entertainment policies, and reporting mechanisms. The policy helps organizations demonstrate their commitment to ethical business practices and provides a framework for preventing, detecting, and responding to corruption-related incidents.

Suggested Sections

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

2. Definitions: Key terms used throughout the policy including 'bribery', 'corruption', 'public official', 'facilitation payments'

3. Policy Statement: Company's zero-tolerance stance on bribery and corruption and commitment to ethical business practices

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

5. Gifts and Hospitality: Guidelines for acceptable and unacceptable practices regarding gifts, entertainment, and hospitality

6. Due Diligence: Requirements for vetting third parties, business partners, and maintaining accurate books and records

7. Reporting Violations: Procedures for reporting suspected violations and whistleblower protection measures

8. Compliance Training: Requirements for employee training and certification on anti-bribery policies

Optional Sections

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

2. Definitions: Key terms used throughout the policy including 'bribery', 'corruption', 'public official', 'facilitation payments'

3. Policy Statement: Company's zero-tolerance stance on bribery and corruption and commitment to ethical business practices

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

5. Gifts and Hospitality: Guidelines for acceptable and unacceptable practices regarding gifts, entertainment, and hospitality

6. Due Diligence: Requirements for vetting third parties, business partners, and maintaining accurate books and records

7. Reporting Violations: Procedures for reporting suspected violations and whistleblower protection measures

8. Compliance Training: Requirements for employee training and certification on anti-bribery policies

Suggested Schedules

1. Gift and Hospitality Register Template: Standard form for recording and tracking gifts, entertainment, and hospitality exchanges

2. Due Diligence Checklist: Comprehensive checklist for vetting third parties and business partners

3. Red Flag Indicators: List of warning signs and indicators of potential corruption or bribery activities

4. Reporting Forms: Standard forms and procedures for reporting violations or concerns

5. Approval Matrix: Matrix showing approval requirements for different types of transactions and value thresholds

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 bribery of foreign officials and mandates accounting transparency. Includes anti-bribery provisions, books and records provisions, and internal controls requirements.

Travel Act: Federal law that prohibits travel or use of interstate facilities in aid of racketeering enterprises, including commercial bribery across state lines or in foreign commerce.

Sarbanes-Oxley Act: Federal law applicable to public companies that establishes requirements for internal controls and financial reporting obligations to prevent and detect corrupt practices.

Dodd-Frank Act: Federal legislation that includes significant whistleblower provisions and protections related to reporting corrupt practices.

UK Bribery Act: Key international legislation to consider when operating in or with UK entities. Often stricter than FCPA and has broader jurisdiction.

OECD Anti-Bribery Convention: International treaty establishing legally binding standards to criminalize bribery of foreign public officials in international business transactions.

UN Convention Against Corruption: International anti-corruption treaty covering prevention measures, criminalization, international cooperation, and asset recovery.

State Commercial Bribery Statutes: Various state-level laws that prohibit commercial bribery and may have specific reporting and compliance requirements.

Anti-Kickback Statute: Healthcare-specific federal law that prohibits the exchange of anything of value to induce or reward referrals of federal healthcare program business.

Government Contracting Regulations: Specific anti-corruption provisions and compliance requirements for companies engaged in government contracts.

State Whistleblower Protection Laws: State-specific legislation providing protection and remedies for employees who report corrupt practices.

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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