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Company Bribery Policy Generator for the USA

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Key Requirements PROMPT example:

Company Bribery Policy

"I need a Company Bribery Policy for my tech startup that's expanding into Asia, with particular focus on third-party due diligence and gift thresholds for government officials, to be implemented by March 2025."

Document background

The Company Bribery Policy has become essential for organizations operating in the United States due to increased regulatory scrutiny and enforcement of anti-corruption laws. This document provides a framework for preventing, detecting, and responding to bribery-related incidents while ensuring compliance with the FCPA and other applicable laws. It addresses various forms of corruption, including commercial bribery, foreign official bribery, and facilitation payments. The policy is particularly crucial for companies engaging in international business or operating in high-risk sectors where interactions with government officials are common.

Suggested Sections

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

2. Definitions: Comprehensive definitions of key terms including bribery, corruption, facilitation payments, and public officials

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

4. Prohibited Conduct: Detailed description of activities that constitute bribery and are strictly forbidden

5. Compliance Procedures: Mandatory steps and procedures employees must follow to ensure compliance with anti-bribery laws

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

Optional Sections

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

2. Definitions: Comprehensive definitions of key terms including bribery, corruption, facilitation payments, and public officials

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

4. Prohibited Conduct: Detailed description of activities that constitute bribery and are strictly forbidden

5. Compliance Procedures: Mandatory steps and procedures employees must follow to ensure compliance with anti-bribery laws

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

Suggested Schedules

1. Gift and Hospitality Guidelines: Detailed thresholds, approval requirements, and procedures for gifts and entertainment

2. Red Flag Indicators: Comprehensive list of warning signs and indicators that may signal bribery risk

3. Approval Forms: Standard templates and forms for seeking approval for potentially sensitive transactions

4. Due Diligence Checklist: Detailed procedures and requirements for vetting third parties and business partners

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 from 1977 that prohibits companies from bribing foreign officials to obtain or retain business. Includes both anti-bribery provisions and accounting transparency requirements.

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

Sarbanes-Oxley Act: 2002 federal law requiring enhanced corporate accountability and financial disclosures, including provisions related to internal controls and financial reporting that affect anti-bribery compliance.

Dodd-Frank Act: Wall Street Reform act that includes whistleblower provisions and incentives for reporting bribery and corruption violations.

State Commercial Bribery Statutes: Various state-level laws that criminalize commercial bribery and corruption within their jurisdictions.

UK Bribery Act: Key international anti-bribery legislation often considered alongside FCPA due to its broad jurisdiction and strict liability provisions for failure to prevent bribery.

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

UN Convention Against Corruption: International anti-corruption treaty addressing prevention, criminalization, international cooperation, and asset recovery related to corruption.

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

Federal Acquisition Regulations: Comprehensive regulations governing government contracting, including anti-bribery and procurement integrity provisions.

Bank Bribery Act: Specific legislation addressing bribery and corruption in the banking and financial services sector.

DOJ FCPA Corporate Enforcement Policy: Department of Justice guidelines for FCPA enforcement, including incentives for voluntary disclosure and cooperation.

SEC Enforcement Guidelines: Securities and Exchange Commission's framework for enforcing anti-bribery and corruption regulations in public companies.

Federal Sentencing Guidelines: Guidelines that provide framework for penalties and mitigation factors in corporate criminal cases, including bribery violations.

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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