Foreign Corrupt Practices Act Policy

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Foreign Corrupt Practices Act Policy
Sample Procedures for Reviewing and Controlling Compliance With the FCPA

This sample policy establishes guidelines organizations should follow with respect to the Foreign Corrupt Practices Act of 1977.

According to this sample, types of conduct that would avoid noncompliance include: the policy prohibits the existence or creation of any undisclosed, secret or unrecorded funds, assets or liabilities; payments on behalf of the company should not be approved or made with the intention or understanding that any part of the payment should be used for purposes other than described by the documents supporting the payment; and the policy prohibits using company assets or funds for purposes other than specifically authorized by management.

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