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The Bribery Prevention Policy serves as a critical compliance tool for organizations operating in the United States. It is designed to address the requirements of the Foreign Corrupt Practices Act (FCPA) and other applicable anti-corruption laws. This document becomes essential when organizations engage in business activities that present corruption risks, particularly in international operations or government contracting. The policy typically includes detailed guidance on gift-giving, entertainment, facilitation payments, and third-party due diligence, while establishing clear reporting channels and investigation procedures.

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

2. Definitions: Detailed definitions of key terms including 'bribery', 'corruption', 'government official', 'facilitation payments', and other relevant terminology

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

4. Prohibited Conduct: Detailed description of prohibited activities, including both public and commercial bribery

5. Due Diligence Requirements: Procedures for vetting third parties, conducting risk assessments, and documentation requirements

6. Gifts and Hospitality: Guidelines for acceptable and prohibited gifts, entertainment, and hospitality

7. Record Keeping: Requirements for maintaining accurate books and records, internal controls, and documentation

8. Reporting and Investigation: Procedures for reporting violations, whistleblower protection, and investigation protocols

9. Training and Communication: Requirements for employee training, certification, and ongoing communication

10. Compliance Monitoring: Procedures for monitoring compliance, conducting audits, and reviewing effectiveness