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Anti Corruption Statement Generator for the USA

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Key Requirements PROMPT example:

Anti Corruption Statement

"Need an Anti-Corruption Statement for our US-based technology startup that's expanding into Asian markets in January 2025, with particular focus on third-party contractor relationships and local business customs."

Document background

The Anti-Corruption Statement has become increasingly important in today's global business environment, where organizations face enhanced scrutiny of their business practices and compliance measures. This document is essential for organizations operating under U.S. jurisdiction, particularly those with international operations or government contracts. The Anti-Corruption Statement typically includes policies on gifts and entertainment, facilitation payments, political contributions, and charitable donations, while establishing clear reporting mechanisms for potential violations. It serves as a key component of an organization's compliance program and helps demonstrate commitment to anti-corruption laws including the FCPA.

Suggested Sections

1. Purpose and Scope: Defines the purpose of the statement and to whom it applies within the organization

2. Anti-Corruption Commitment: Clear statement of zero tolerance for bribery and corruption, including reference to key legislation like FCPA

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

4. Compliance Requirements: Specific procedures and controls that must be followed to prevent corruption, including record-keeping requirements

5. Reporting Procedures: Process for reporting violations, whistleblower protections, and non-retaliation policy

Optional Sections

1. Purpose and Scope: Defines the purpose of the statement and to whom it applies within the organization

2. Anti-Corruption Commitment: Clear statement of zero tolerance for bribery and corruption, including reference to key legislation like FCPA

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

4. Compliance Requirements: Specific procedures and controls that must be followed to prevent corruption, including record-keeping requirements

5. Reporting Procedures: Process for reporting violations, whistleblower protections, and non-retaliation policy

Suggested Schedules

1. Red Flag Indicators: Comprehensive list of warning signs that might indicate corruption risk

2. Compliance Certification Form: Template for employees to certify their understanding and compliance with the anti-corruption statement

3. Due Diligence Checklist: Standard checklist for evaluating third parties and business partners

4. Gift and Hospitality Register Template: Standard template for recording gifts, entertainment, and hospitality given or received

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, requires proper accounting practices and internal controls. Applies to U.S. companies and individuals, and foreign companies listed on U.S. stock exchanges.

Federal Anti-Kickback Statute: Federal law particularly relevant for healthcare industry that prohibits knowingly offering or receiving kickbacks for federal healthcare program business.

Travel Act: Federal legislation that can be used to prosecute commercial bribery cases across state lines.

State Anti-Corruption Laws: Various state-specific anti-bribery and corruption statutes that may apply depending on jurisdiction.

UN Convention Against Corruption (UNCAC): International anti-corruption treaty to which the United States is a signatory, providing global standards for anti-corruption measures.

OECD Anti-Bribery Convention: International standards for combating bribery in international business transactions, establishing legally binding standards.

UK Bribery Act: British legislation often considered alongside FCPA due to its broad territorial reach and relevance for organizations with UK connections.

DOJ/SEC FCPA Resource Guide: Regulatory guidance document providing interpretation and enforcement information for FCPA compliance.

U.S. Sentencing Guidelines: Federal guidelines providing standards for compliance programs and penalties for corporate wrongdoing.

DOJ Corporate Enforcement Policy: Department of Justice guidelines outlining expectations for voluntary disclosure and cooperation in corruption cases.

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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