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Bribery & Corruption Policy Generator for the USA

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Key Requirements PROMPT example:

Bribery & Corruption Policy

"Need a comprehensive Bribery & Corruption Policy for our new technology startup that's expanding into Southeast Asian markets in March 2025, with particular focus on third-party due diligence and digital payment systems."

Document background

The Bribery & Corruption Policy is essential for organizations operating in the United States to maintain compliance with federal and state anti-corruption laws, particularly the FCPA. This document is typically implemented when companies need to establish clear guidelines for ethical business conduct, especially when operating in high-risk markets or industries. The policy addresses various aspects of anti-corruption compliance, including gift-giving, facilitation payments, political contributions, and third-party due diligence. It serves as a crucial tool for risk management and maintaining corporate integrity.

Suggested Sections

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

2. Policy Statement: Clear statement of zero-tolerance approach to bribery and corruption

3. Definitions: Key terms including bribery, corruption, facilitation payments, public officials

4. Prohibited Conduct: Specific activities and behaviors that are prohibited under the policy

5. Reporting and Investigation: Procedures for reporting violations and investigation protocols

6. Training and Communication: Requirements for employee training and policy communication

7. Compliance Monitoring: Methods for monitoring and reviewing policy compliance

Optional Sections

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

2. Policy Statement: Clear statement of zero-tolerance approach to bribery and corruption

3. Definitions: Key terms including bribery, corruption, facilitation payments, public officials

4. Prohibited Conduct: Specific activities and behaviors that are prohibited under the policy

5. Reporting and Investigation: Procedures for reporting violations and investigation protocols

6. Training and Communication: Requirements for employee training and policy communication

7. Compliance Monitoring: Methods for monitoring and reviewing policy compliance

Suggested Schedules

1. Gift and Hospitality Register Template: Standard form for recording gifts and hospitality

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

3. Red Flag Indicators: List of warning signs that might indicate corrupt practices

4. Reporting Form: Template for reporting suspected violations

5. Training Log: Template for recording 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

FCPA: Foreign Corrupt Practices Act - The primary U.S. federal law that prohibits the payment of bribes to foreign government officials to assist in obtaining or retaining business

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

Sarbanes-Oxley Act: Federal law that sets requirements for all U.S. public company boards, management, and public accounting firms, including provisions related to internal controls and financial reporting

Dodd-Frank Act: Wall Street Reform and Consumer Protection Act that includes whistleblower provisions and anti-corruption measures in the financial sector

Federal Anti-Kickback Statute: Law prohibiting the exchange (or offer to exchange) of anything of value in an effort to induce or reward the referral of federal healthcare program business

State Anti-Corruption Laws: Various state-specific laws that address corruption and bribery at the state level

UK Bribery Act: Key international legislation to consider if operating globally - broader in scope than FCPA and includes private sector bribery

OECD Anti-Bribery Convention: International treaty requiring signatory countries to criminalize bribery of foreign public officials in international business transactions

UNCAC: United Nations Convention Against Corruption - The only legally binding universal anti-corruption instrument

DOJ Corporate Enforcement Policy: Department of Justice guidelines for corporate enforcement of anti-corruption laws, including voluntary disclosure incentives

SEC Guidelines: Securities and Exchange Commission enforcement guidelines for anti-corruption compliance and reporting

Federal Sentencing Guidelines: Guidelines that provide incentives for organizations to maintain effective compliance programs

FCPA Resource Guide: Comprehensive guidance document jointly published by DOJ and SEC providing detailed information about FCPA compliance

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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