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Global Anti Bribery Policy Generator for the USA

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Key Requirements PROMPT example:

Global Anti Bribery Policy

"Need a Global Anti Bribery Policy for our technology startup that's expanding into Asia and Europe in January 2025, with particular focus on software licensing and third-party reseller relationships."

Document background

The Global Anti Bribery Policy serves as a fundamental compliance document for organizations operating internationally. It is designed to address the increasing scrutiny from regulatory authorities and the need for transparent business practices. The policy incorporates requirements from the U.S. FCPA, international conventions, and local anti-corruption laws, providing a framework for preventing bribery, managing third-party relationships, and maintaining accurate books and records. Organizations implement this policy to demonstrate their commitment to ethical business practices and to protect against legal and reputational risks.

Suggested Sections

1. Purpose and Scope: States the policy's objective and who/what entities it applies to

2. Policy Statement: Clear statement of zero tolerance for bribery and corruption

3. Definitions: Key terms including 'bribery', 'corruption', 'government official', 'facilitation payments'

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

5. Prohibited Conduct: Specific activities that constitute violations of the policy

6. Gifts and Entertainment: Rules and thresholds for acceptable business courtesies

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

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

9. Reporting Violations: Procedures for reporting suspected violations

Optional Sections

1. Purpose and Scope: States the policy's objective and who/what entities it applies to

2. Policy Statement: Clear statement of zero tolerance for bribery and corruption

3. Definitions: Key terms including 'bribery', 'corruption', 'government official', 'facilitation payments'

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

5. Prohibited Conduct: Specific activities that constitute violations of the policy

6. Gifts and Entertainment: Rules and thresholds for acceptable business courtesies

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

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

9. Reporting Violations: Procedures for reporting suspected violations

Suggested Schedules

1. Red Flag Indicators: List of warning signs indicating potential corruption risks

2. Approval Matrix: Authority levels for approving various types of expenses

3. Due Diligence Questionnaire: Standard form for vetting third parties

4. Gift Register Template: Standard form for recording gifts and entertainment

5. Country-Specific Guidelines: Specific thresholds and 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-bribery legislation 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 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: Contains important whistleblower provisions and protections for individuals who report securities violations, including foreign bribery

State Anti-Bribery Laws: Various state-specific legislation dealing with commercial bribery and public corruption at the state level

UK Bribery Act: Comprehensive anti-bribery legislation from the United Kingdom with extraterritorial reach, often considered alongside FCPA due to its broad jurisdiction

OECD Anti-Bribery Convention: International convention establishing legally binding standards 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 that provides a framework for preventing and combating corruption

Securities Exchange Act: U.S. legislation governing securities markets and requiring specific disclosures related to anti-corruption compliance

Federal Sentencing Guidelines: Guidelines that provide framework for corporate compliance programs and influence how companies are treated in case of violations

DOJ Guidance: Department of Justice guidance documents on FCPA enforcement and compliance program expectations

SEC Guidance: Securities and Exchange Commission guidance on anti-corruption compliance and enforcement priorities

International Trade Regulations: Regulations governing international business transactions that intersect with anti-corruption compliance

Money Laundering Regulations: Laws and regulations designed to prevent the processing of criminal proceeds, often interconnected with anti-bribery compliance

Whistleblower Protection Laws: Various laws protecting individuals who report potential violations of anti-corruption laws

Industry-Specific Regulations: Sector-specific anti-corruption requirements that may apply depending on the company's industry

Books and Records Requirements: Requirements for maintaining accurate corporate books and records and adequate internal accounting controls

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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