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Global Anti Bribery And Corruption Policy Generator for the USA

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Key Requirements PROMPT example:

Global Anti Bribery And Corruption Policy

"I need a Global Anti Bribery And Corruption Policy for my technology company that's expanding into Asia and South America in March 2025, with particular emphasis on third-party due diligence and specific provisions for software licensing and technology transfer transactions."

Document background

The Global Anti Bribery And Corruption Policy is essential for organizations operating in multiple jurisdictions to maintain compliance with various anti-corruption laws, particularly the U.S. FCPA. This policy document is typically implemented when companies expand internationally or need to strengthen their compliance framework. It provides detailed guidance on preventing corrupt practices, managing third-party relationships, handling gifts and entertainment, and maintaining accurate books and records. The policy helps organizations minimize legal and reputational risks while promoting ethical business practices across their global operations.

Suggested Sections

1. Introduction and Purpose: States the company's commitment to ethical business practices and compliance with anti-corruption laws

2. Scope and Applicability: Defines who the policy applies to (employees, contractors, subsidiaries, third parties)

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

4. Legal Framework: Overview of applicable laws (FCPA, UK Bribery Act, local laws)

5. General Prohibitions: Core anti-bribery and corruption rules and prohibited conduct

6. Gifts and Hospitality: Rules and thresholds for giving/receiving gifts and entertainment

7. Third Party Due Diligence: Requirements for vetting and monitoring third parties

8. Books and Records: Requirements for accurate recording of transactions and internal controls

9. Reporting and Investigation: Procedures for reporting violations and investigation process

Optional Sections

1. Introduction and Purpose: States the company's commitment to ethical business practices and compliance with anti-corruption laws

2. Scope and Applicability: Defines who the policy applies to (employees, contractors, subsidiaries, third parties)

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

4. Legal Framework: Overview of applicable laws (FCPA, UK Bribery Act, local laws)

5. General Prohibitions: Core anti-bribery and corruption rules and prohibited conduct

6. Gifts and Hospitality: Rules and thresholds for giving/receiving gifts and entertainment

7. Third Party Due Diligence: Requirements for vetting and monitoring third parties

8. Books and Records: Requirements for accurate recording of transactions and internal controls

9. Reporting and Investigation: Procedures for reporting violations and investigation process

Suggested Schedules

1. Gift and Hospitality Thresholds: Detailed monetary limits for different types of gifts and entertainment

2. Red Flag Indicators: List of warning signs for potential corruption risks

3. Due Diligence Questionnaire: Standard form for third party due diligence

4. Approval Matrix: Authorization levels for various types of transactions

5. Training Requirements: Schedule of required training by role/risk level

6. Country-Specific Requirements: Local law variations and additional requirements by jurisdiction

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

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Industries

FCPA: Foreign Corrupt Practices Act - Primary U.S. anti-corruption law that prohibits the payment of bribes to foreign officials to assist in obtaining or retaining business

Travel Act: U.S. federal law that prohibits travel or use of facilities in interstate commerce to promote unlawful activities, including commercial bribery

Sarbanes-Oxley Act: U.S. 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: U.S. legislation that includes significant whistleblower provisions and protections relevant to anti-corruption compliance

UK Bribery Act: Comprehensive UK anti-bribery legislation with extraterritorial reach, often considered alongside FCPA due to its broad jurisdiction and stricter provisions

OECD Anti-Bribery Convention: International anti-bribery 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

Anti-Kickback Statute: Healthcare-specific legislation prohibiting the exchange (or offer to exchange) of anything of value in an effort to induce federal healthcare program business

Federal Acquisition Regulations: Comprehensive set of rules governing the federal government's purchasing process, including anti-corruption provisions for government contractors

Bank Secrecy Act: U.S. legislation requiring financial institutions to assist government agencies in detecting and preventing money laundering, including corruption-related proceeds

EU Anti-Corruption Laws: Collection of European Union directives and regulations designed to combat corruption across EU member states

AML Regulations: Anti-Money Laundering regulations that often intersect with anti-corruption compliance, particularly in detecting and preventing the flow of corrupt payments

Economic Sanctions Regulations: Regulations restricting business with certain countries, entities, or individuals, often related to corruption and other illegal activities

Export Control Laws: Regulations governing the export of goods and services, including provisions to prevent corruption in international trade

Competition/Antitrust Laws: Laws protecting market competition that often overlap with anti-corruption compliance, particularly in bid-rigging and market manipulation scenarios

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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