The US Foreign Corrupt Practices Act guidance published by US government

Size: px
Start display at page:

Download "The US Foreign Corrupt Practices Act guidance published by US government"

Transcription

1 Briefing The US Foreign Corrupt Practices Act guidance published by US government Summary US government guidance provides helpful collection of principles and case law, but does little to clarify areas of uncertainty in the US FCPA. On 14, the US Department of Justice (DOJ) and Securities and Exchange Commission (SEC) jointly published A Resource Guide to the US Foreign Corrupt Practices Act (the Guide). The 120-page booklet includes a combination of general principles, examples from actual cases (documented in an appendix of 418 endnotes of legal citations), and hypothetical illustrations. This note provides an immediate analysis of a number of key areas covered by the guide. For more information please contact Marius Berenbrok Hamburg T Geoff Nicholas Hong Kong T Adam Siegel T Tim Coleman Washington T Aaron Marcu T Benito Romano T Freshfields Bruckhaus Deringer llp The US Foreign Corrupt Practices Act 1

2 The guidance The long-awaited guide, which has been in development for the last year, provides information that will be useful for basic training on FCPA concepts. It will also be a handy reference tool for lawyers (especially the endnotes). But there is little in the guide that will be new to compliance professionals who are familiar with the FCPA. Ultimately, the guide raises more questions than it answers. Compliance professionals seeking clear and practical answers to everyday questions from the global workforce will find little here. However, what the guide does make clear is that the US authorities will continue to interpret the FCPA ever more expansively, building on their own prior settlement agreements (as opposed to judicial precedent) to broaden the law s jurisdictional reach and the scope of business activity it prohibits. That approach is reflected in the highlights discussed below. Businesses will continue to confront the risk of a US enforcement regime that is active, aggressive, and rather unpredictable. Jurisdiction The guidance does nothing to limit the everexpanding view of US jurisdiction.the US will continue to vigorously enforce the FCPA wherever there is a minimal nexus to the US. Forward-thinking companies, whether operating in the US or elsewhere, should continue to consider their potential liability under the FCPA. The statute s jurisdictional reach is broad and growing, as seen by the aggressive stance in the guide and in recent enforcement actions. Liability does not end with US businesses and issuers of securities on US exchanges. The FCPA also applies to non-us companies and their agents, even those without any US operations, that take any act within the US in furtherance of a corrupt payment to an official. Additionally, non-us companies and persons may also be liable if they conspire with or aid and abet an FCPA violation committed by a person who is subject to the law. US prosecutors believe they have jurisdiction even where there is little, if any, connection to or activity within the US. The guide formalizes what the DOJ has been saying for years: placing a telephone call, or sending an , text message, fax, or wire transfer from, to, or through the US, or any other use of the US banking system, can trigger FCPA liability. Notably, however, DOJ prosecutions of non-us companies to date have been limited to companies with American Depository Receipts on a US exchange. The guide is careful to place its expansive (even a single ) view of jurisdiction in a paragraph discussing US issuers and US companies, separate from a discussion of non-us entities. While the guide modestly acknowledges that the FCPA does not cover every type of bribe paid around the world for every purpose, it does not offer any practical limitations on its application. This is despite a federal judge s recent criticism of the government s jurisdictional position, US Congressional hearings, and repeated demands from the business sector. This means that for non-us companies, even with very little connection to the US there are few places where corporate bribery, in any form, will escape liability or related legal costs. Definition of foreign official instrumentalities The guide contains a long list of non-exclusive factors to consider when determining whether a state-owned or state-controlled entity is an instrumentality of a state and thus subject to the FCPA. The FCPA prohibits corrupt payments to a foreign official, which is broadly defined to include officers and employees of governments and government instrumentalities, as well as persons acting on behalf of such entities. The DOJ has stated that this prohibition applies to payments to any public official, regardless of rank or position. However the DOJ has recently created confusion by condoning payments to certain de facto officials in certain circumstances (for example, a royal family member). 2 Freshfields Bruckhaus Deringer llp The US Foreign Corrupt Practices Act

3 The guide states that the critical question of whether a state-owned or state-controlled entity is an instrumentality has no bright line guiding principle. Instead, it requires a fact-specific analysis. The guide then repeats a list of eleven non-exclusive factors used recently by three courts that have considered the issue. (The guide does not, however, recognize that one of those cases is on appeal). The non-exhaustive list includes factors such as the foreign state s extent of ownership of the entity and its degree of control over the entity, the purpose of the entity s activities, the level of financial support by the foreign state and the general perception that the entity is performing official or governmental functions. The guide struggles to keep up with the changing business environment in which state-directed capitalism has a growing role. For example, as of 2011, state-controlled companies in emerging markets comprised approximately 65% of the energy sector, 55% of utilities, and 35% of the telecommunications and financial services sectors, according to The Economist. The guide also fails to offer any new guidance on the circumstances in which a person who is not employed by a government or instrumentality but acts on behalf of such an entity may be subject to the FCPA. Third party vetting The guide emphasizes the importance of due diligence on third parties and lists a number of red flags. The guide cautions companies to be aware of the risks involved in engaging third-party agents or intermediaries. Indeed, in many of the examples in the guide, the main FCPA offender is a third party. The US agencies leave little doubt about their skeptical view of these parties. The guide states categorically that third parties, including agents, consultants, and distributors, are commonly used to conceal the payment of bribes to foreign officials in international business transactions. The guide states that even without actual knowledge that a bribe will be paid by a third party, persons may be liable if they are aware of a high probability that a bribe would be paid. However it offers no discussion of when or how a red flag may represent a high probability of an improper payment. This remains an open issue for companies to evaluate carefully. The guide urges companies to conduct due diligence on intermediaries. It prescribes a vetting process which includes exploring the party s reputation and relationships (especially with government officials), scrutinizing their payment terms, and carefully documenting the services they provide. In riskier circumstances, the guide suggests that companies should conduct FCPA training for third parties, require them to certify their compliance with anticorruption laws, and demand the right to audit their internal records. This approach will often involve considerable expense and commercial risk. Too much due diligence can jeopardize an important transaction and waste time and money. Too little may be viewed by the US authorities (with benefit of hindsight) as insufficient. In substantial transactions involving thirdparty intermediaries, it would be prudent to obtain professional advice on the appropriate level of due diligence. No compliance program defense The guide acknowledges that there are benefits for companies in having a robust compliance program, but it is unclear to what extent this will mitigate a company s liability. The SEC s director of enforcement said the guide is intended to make it clear how we reward companies to adopt compliance programs that are effective in preventing violations in the first place. If you were expecting the government to announce how to escape liability for the acts of rogue employees and agents, or to announce some numerical value or percentage that your penalty may be decreased by having a compliance program, prepare for disappointment. Freshfields Bruckhaus Deringer llp The US Foreign Corrupt Practices Act 3

4 The guide does not create any formal compliance defense to the FCPA, despite US Congressional hearings on the merits of such an option and repeated calls from companies to consider compliance programs more seriously. While recognizing that no compliance program can be perfect, the guide merely states that a compliance program may influence an enforcement decision and will often affect a penalty amount. The coveted defense could have allowed companies with pre-existing compliance policies and procedures, and a good faith commitment to FCPA compliance, to rebut criminal liability (or concretely reduce penalties) for FCPA violations committed by rogue employees and agents who act contrary to those policies and procedures in the same way as the UK Bribery Act. However, the DOJ seems to be concerned that such a defense could lead to a check-the-box approach being adopted by companies. The DOJ and SEC already take a company s compliance program into account when assessing whether to prosecute, or what settlement terms to offer, and the US sentencing guidelines allow courts to credit companies compliance efforts at sentencing. Without an affirmative compliance defense, companies must continue to look to the guide (which borrows heavily from the UK Bribery Act s guidance on adequate procedures) as well as past cases of FCPA enforcement that have required peers to create or enhance compliance programs to discern what the US government considers to be compliance best practices. Going forward companies will be expected to focus on standards and procedures that are risk-based and industry-specific, enhanced third-party due diligence, and periodic testing and review of companies compliance programs. Finally, while monitorships are on the wane in numerical terms, the guide states that they may still be appropriate where companies lack an effective compliance or internal controls. The US has missed an opportunity to align itself with the UK and other countries that are increasingly looking to provide companies with a compliance defense. The UK Bribery Act 2010 provides a full defense to liability if a corporate entity can show it had adequate procedures in place, proportionate to risk, and intended to detect and deter improper conduct. In addition, at least 16 countries have some form of adequate procedures defense and such a defense is currently under discussion in Brazil. Nearly 60 other countries, though not providing for a defense, nevertheless state that compliance procedures would likely be viewed favorability as a mitigating factor. It seems apparent that if companies feel the need for an FCPA compliance defense, they should turn to the US Congress. Gifts and hospitality The guide describes the extremes of what is clearly not an FCPA issue and what clearly would be but leaves companies with a wide gap between the extremes. The guide describes the patterns that have emerged with gifts and hospitality: enforcement involving small payments and gifts occurs only when they comprise part of a systemic or long-standing course of conduct that evidences a scheme to corruptly pay foreign officials, or where there are clear indicia of corrupt intent. The guide takes pains to emphasize that the FCPA does not prohibit a small gift or token of esteem or gratitude, and does not forbid moderate hospitality. (In this respect it is similar to a recent statement by the UK Serious Fraud Office in the context of the UK Bribery Act). In releasing the guide, the SEC s director of enforcement explained: it is not the $5 cup of coffee, or the one off $50 gift to a public official, that companies need to be concerned about, but payments of real and substantial value that clearly represent an unambiguous intent to bribe a foreign official to obtain or retain business. However, the guide leaves no doubt that the US will consider gifts or hospitality illegal if 4 Freshfields Bruckhaus Deringer llp The US Foreign Corrupt Practices Act

5 it deems them too large or immoderate, on the theory that they are bribes in disguise. The examples in the guide do little to illuminate the grey area between acceptable and plainly inappropriate gifts (like the gift of a fur coat). What the examples do make abundantly clear is that the US will continue to scrutinize payments of travel and entertainment expenses, especially in the context of training exercises and site inspections. US prosecutors will consider such factors as the airline class of service, the cost of meals, and the mix of business and social events in deciding whether the payment of expenses is an illegal bribe in disguise. This type of scrutiny reinforces the importance of obtaining professional advice before agreeing to pay the cost of a foreign customer s visit to a company site for training or facility inspection. By documenting that the expense has been approved in reliance on professional advice, the company can protect itself from FCPA charges. Companies should also consider adopting monetary thresholds, annual limits and automated clearance processes for gifts, travel and entertainment expenses. The guide suggests that such measures are favored by the US authorities. freshfields.com Freshfields Bruckhaus Deringer llp is a limited liability partnership registered in England and Wales with registered number OC It is authorised and regulated by the Solicitors Regulation Authority. For regulatory information please refer to Any reference to a partner means a member, or a consultant or employee with equivalent standing and qualifications, of Freshfields Bruckhaus Deringer llp or any of its affiliated firms or entities. This material is for general information only and is not intended to provide legal advice. Freshfields Bruckhaus Deringer llp,

CARDINAL RESOURCES LLC INTRODUCTION

CARDINAL RESOURCES LLC INTRODUCTION CARDINAL RESOURCES LLC ANTI- BRIBERY AND ANTI- CORRUPTION POLICY INTRODUCTION The purpose of this Anti- bribery and Anti- corruption Policy (the "Policy") is to ensure compliance by the Red Bird Group

More information

The Long Arm of the U.S. Foreign Corrupt Practices Act: Complying with the FCPA in the Vietnamese Landscape

The Long Arm of the U.S. Foreign Corrupt Practices Act: Complying with the FCPA in the Vietnamese Landscape The Long Arm of the U.S. Foreign Corrupt Practices Act: Complying with the FCPA in the Vietnamese Landscape Foreign Corrupt Practices Act: The Act What is the Act? Anti-Bribery Provisions Book and Record

More information

Anti-Bribery Provisions of the Foreign Corrupt Practices Act: Application to Foreign Corporations and Individuals

Anti-Bribery Provisions of the Foreign Corrupt Practices Act: Application to Foreign Corporations and Individuals Anti-Bribery Provisions of the Foreign Corrupt Practices Act: Application to Foreign Corporations and Individuals LeClairRyan Carlos F. Ortiz 973.491.3365 carlos.ortiz@leclairryan.com Valerie C. Charles

More information

HILLENBRAND, INC. AND SUBSIDIARIES. Global Anti-Corruption Policy Statement and Compliance Guide

HILLENBRAND, INC. AND SUBSIDIARIES. Global Anti-Corruption Policy Statement and Compliance Guide HILLENBRAND, INC. AND SUBSIDIARIES Global Anti-Corruption Policy Statement and Compliance Guide Hillenbrand, Inc., including all of its subsidiaries (referred to collectively as the Company ), maintains

More information

PHILIP H. HILDER H I L D E R A N D A S S O C I A T E S, P. C. 8 1 9 L O V E T T B L V D. H O U S T O N, T E X A S 7 7 0 0 6 7 1 3-6 5 5-9 1 1 1 W W W

PHILIP H. HILDER H I L D E R A N D A S S O C I A T E S, P. C. 8 1 9 L O V E T T B L V D. H O U S T O N, T E X A S 7 7 0 0 6 7 1 3-6 5 5-9 1 1 1 W W W FCPA Now and Later PHILIP H. HILDER H I L D E R A N D A S S O C I A T E S, P. C. 8 1 9 L O V E T T B L V D. H O U S T O N, T E X A S 7 7 0 0 6 7 1 3-6 5 5-9 1 1 1 W W W. H I L D E R L A W. C O M Purpose

More information

ANTI-CORRUPTION AND ANTI-BRIBERY POLICY

ANTI-CORRUPTION AND ANTI-BRIBERY POLICY COMPLIANCE 18.0 ANTI-CORRUPTION AND ANTI-BRIBERY POLICY I. SCOPE This policy applies to all directors, officers, employees, agents, and shareholders of UHS of Delaware, Inc. (hereafter, UHS ), its subsidiaries

More information

FCPA and International Compliance

FCPA and International Compliance FCPA and International Compliance Briefing to San Antonio Post, SAME C. Ernest Edgar IV General Counsel, Atkins North America 1 Agenda Understanding the FCPA The Nuts and Bolts of the FCPA Who Is Covered

More information

CC255 C O R P O R A T E. Altus FCPA Policy. Last revised: 12 October 2010

CC255 C O R P O R A T E. Altus FCPA Policy. Last revised: 12 October 2010 CC255 Altus FCPA Policy Last revised: 12 October 2010 C O R P O R A T E Foreign Corrupt Practices Act Policy Purpose The purpose of this Policy is to ensure compliance by Altus and its directors, officers,

More information

ANTI-CORRUPTION COMPLIANCE GUIDELINES

ANTI-CORRUPTION COMPLIANCE GUIDELINES ANTI-CORRUPTION COMPLIANCE GUIDELINES INTRODUCTION These guidelines establish procedures for handling, and should help you identify anti-corruption concerns. If you are ever uncertain or feel uneasy about

More information

Foreign Corrupt Practices Act Policy August 19, 2015

Foreign Corrupt Practices Act Policy August 19, 2015 I. PURPOSE To provide guidelines to all officers, directors, employees, consultants and agents that are employed by the Company to ensure compliance with the Foreign Corrupt Practices Act of the United

More information

SEMGROUP CORPORATION. Anti-Corruption Compliance Policy August, 2011

SEMGROUP CORPORATION. Anti-Corruption Compliance Policy August, 2011 SEMGROUP CORPORATION Anti-Corruption Compliance Policy August, 2011 SCOPE This is a global policy (the Policy ) applicable to the worldwide operations of SemGroup Corporation ("SemGroup") and all of its

More information

IFA s 45 th Annual LEGAL SYMPOSIUM

IFA s 45 th Annual LEGAL SYMPOSIUM LEGAL SYMPOSIUM The Foreign Corrupt Practices Act: What Every International Franchisor Must Know Moderator: Speakers: Eric L. Yaffe Gray Plant Mooty Washington, DC Mary C. Spearing Baker Botts L.L.P. Washington,

More information

Amgen GLOBAL CORPORATE COMPLIANCE POLICY

Amgen GLOBAL CORPORATE COMPLIANCE POLICY 1. Scope Applicable to all Amgen Inc. and subsidiary or affiliated company staff members, consultants, contract workers and temporary staff worldwide ( Covered Persons ). Consultants, contract workers,

More information

U.S. Foreign Corrupt Practices Act for Beginners

U.S. Foreign Corrupt Practices Act for Beginners U.S. Foreign Corrupt Practices Act for Beginners This presentation, related materials and subsequent discussion are provided for educational purposes only. They do not constitute legal advice nor do they

More information

PHOENIX NEW MEDIA LIMITED FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY

PHOENIX NEW MEDIA LIMITED FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY PHOENIX NEW MEDIA LIMITED FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY Phoenix New Media Limited (together with its subsidiaries, the Company ) is committed to conducting all aspects of its business

More information

Worldwide Anti-Corruption Policy

Worldwide Anti-Corruption Policy Worldwide Anti-Corruption Policy I. PURPOSE The laws of most countries make the payment or offer of payment or even receipt of a bribe, kickback or other corrupt payment a crime, subjecting both Eaton

More information

MIDMARK CORPORATION FCPA COMPLIANCE POLICY

MIDMARK CORPORATION FCPA COMPLIANCE POLICY MIDMARK CORPORATION FCPA COMPLIANCE POLICY I. INTRODUCTION The purpose of this guide is to provide all Midmark Corporation teammates an overview of the Foreign Corrupt Practices Act (FCPA) and its application

More information

PROTIVITI FLASH REPORT

PROTIVITI FLASH REPORT PROTIVITI FLASH REPORT Even Retailers and Consumer Products Manufacturers Must Manage Compliance with the U.S. Foreign Corrupt Practices Act and Other Anti-Bribery Laws May 3, 2012 Recent reports of alleged

More information

Complying with the U.S. Foreign Corrupt Practices Act

Complying with the U.S. Foreign Corrupt Practices Act Complying with the U.S. Foreign Corrupt Practices Act 1. About This Manual This Manual describes the Foreign Corrupt Practices Act ( FCPA ), 15 U.S.C. 78m, 78dd, 78ff (collectively, FCPA ), anti-corruption

More information

A Comparison of the U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act

A Comparison of the U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act October 2010 A Comparison of the U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act BY MICHELLE DUNCAN, PALMINA FAVA & SAMANTHA KAKATI Introduction The U.S. is the global leader in enforcing anti-corruption

More information

Anti-Corruption: An Overview for I.R. Professionals

Anti-Corruption: An Overview for I.R. Professionals Anti-Corruption: An Overview for I.R. Professionals Presented by Stephen Double May 1, 2012 New York City Pop Quiz 2 True or False? A publicly owned German company that has stock traded on a U.S. stock

More information

Model Anti-Bribery Policy/FCPA Version

Model Anti-Bribery Policy/FCPA Version Model Anti-Bribery Policy/FCPA Version Model Anti-Bribery Policy/FCPA Version This model anti-bribery policy template is intended to assist organizations in creating a values-based anti-bribery and anti-corruption

More information

How Hedge Funds and Private Equity Firms Can Manage Foreign Corrupt Practices Act Risks

How Hedge Funds and Private Equity Firms Can Manage Foreign Corrupt Practices Act Risks How Hedge Funds and Private Equity Firms Can Manage Foreign Corrupt Practices Act Risks Edward T. Kang and Brian D. Frey of Alston & Bird LLP In recent years, the Department of Justice (DOJ) and the Securities

More information

Foreign Corrupt Practices Act:

Foreign Corrupt Practices Act: Foreign Corrupt Practices Act: A Guide to U.S. Anti-Bribery Law Roger J. Magnuson 1 1 Guide to U.S. Anti-Bribery Law Foreign Corrupt Practices Act Three Components to this Presentation: Overview of the

More information

MUELLER INDUSTRIES, INC. ANTICORRUPTION POLICY

MUELLER INDUSTRIES, INC. ANTICORRUPTION POLICY MUELLER INDUSTRIES, INC. ANTICORRUPTION POLICY THIS POLICY HAS BEEN APPROVED BY THE BOARD OF DIRECTORS OF MUELLER INDUSTRIES, INC. ON FEBRUARY 11, 2010 AND IS APPLICABLE TO ALL DIRECTORS, OFFICERS, EMPLOYEES,

More information

ANTI-BRIBERY AND FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY

ANTI-BRIBERY AND FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY Issued: November 12, 2013 ANTI-BRIBERY AND FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY SCOPE This policy applies to all Magnetek, Inc. ( Magnetek ) employees, its subsidiaries and affiliates worldwide,

More information

FCPA: DOJ and SEC Guidance (Part 2) Parent-Subsidiary and Successor Liability

FCPA: DOJ and SEC Guidance (Part 2) Parent-Subsidiary and Successor Liability Introduction FCPA: DOJ and SEC Guidance (Part 2) Parent-Subsidiary and Successor Liability In this second part of our client alert series on the Foreign Corrupt Practices Act ( FCPA ), we focus on how

More information

Foreign Corrupt Practices Act Compliance

Foreign Corrupt Practices Act Compliance Document ID: LGL-D010 Rev 0 February 11, 2010 Page 1 of 6 Applies to: Aerojet Document Owners: Vice President, General Counsel and Executive Director, Contracts, Ethics & Compliance Purpose Background

More information

Anti-Corruption Compliance Guidance

Anti-Corruption Compliance Guidance Anti-Corruption Compliance Guidance Global Supplement for working with Public Officials May 2015 Hong Kong Zhuhai Macau Crossing Hong Kong Tideway Tunnel Improvements London, England U.S. Forces Korea

More information

Introduction to the U.S. Foreign Corrupt Practices Act

Introduction to the U.S. Foreign Corrupt Practices Act Introduction to the U.S. Foreign Corrupt Practices Act Pablo C. Ferrante June 2010 Partner 713-238-2662 pferrante@mayerbrown.com Mayer Brown is a global legal services organization comprising legal practices

More information

MACLEAN-FOGG COMPANY FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY

MACLEAN-FOGG COMPANY FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY MACLEAN-FOGG COMPANY FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY MacLean-Fogg s corporate policy prohibits all improper or unethical payments to government officials anywhere in the world. This is

More information

Introduction to the Foreign Corrupt Practices Act (a training presentation for employees)

Introduction to the Foreign Corrupt Practices Act (a training presentation for employees) Introduction to the Foreign Corrupt Practices Act (a training presentation for employees) Introduction Thank you for participating in our Foreign Corrupt Practices Act (FCPA) training program. [Our Company]

More information

A Summary of U.S. Law Against the Bribery of Foreign Officials:

A Summary of U.S. Law Against the Bribery of Foreign Officials: Fall Winter 2005 A Summary of U.S. Law Against the Bribery of Foreign Officials: The U.S. Foreign Corrupt Practices Act The U.S. Foreign Corrupt Practices Act (the FCPA ) prohibits corrupt payments to

More information

Application of the Foreign Corrupt Practices Act in China

Application of the Foreign Corrupt Practices Act in China Application of the Foreign Corrupt Practices Act in China Introduction U.S. companies and their subsidiaries in China must have an adequate Foreign Corrupt Practices Act ( FCPA ) compliance program. Doing

More information

What You Need to Know About the FCPA

What You Need to Know About the FCPA What You Need to Know About the FCPA May 12, 2016 Richard E. Weiner Fredrikson & Byron, P.A. Understanding The Legal Risks The FCPA prohibits: Improper payments and other practices in connection with overseas

More information

DIGITAL RIVER, INC. FOREIGN CORRUPT PRACTICES ACT AND ANTI-BRIBERY POLICY. (Adopted by resolution of the Board of Directors on December 1, 2011)

DIGITAL RIVER, INC. FOREIGN CORRUPT PRACTICES ACT AND ANTI-BRIBERY POLICY. (Adopted by resolution of the Board of Directors on December 1, 2011) DIGITAL RIVER, INC. FOREIGN CORRUPT PRACTICES ACT AND ANTI-BRIBERY POLICY (Adopted by resolution of the Board of Directors on December 1, 2011) Digital River, Inc. and our affiliates ( DR ) must comply

More information

Anti-Corruption and FCPA Compliance Policy

Anti-Corruption and FCPA Compliance Policy Anti-Corruption and FCPA Compliance Policy Purpose and Scope Vicor Corporation ( Vicor or the Company ) must comply with the U.S. Foreign Corrupt Practices Act of 1977, as amended (the "FCPA") and all

More information

Fraud-Related Compliance

Fraud-Related Compliance Fraud-Related Compliance Areas of Compliance, Part 1: FCPA, SOX, PCAOB, Dodd-Frank 2015 Association of Certified Fraud Examiners, Inc. Foreign Corrupt Practices Act (FCPA) Enacted to prohibit corrupt payments

More information

Administrative Policy No. AD 2.26 Title:

Administrative Policy No. AD 2.26 Title: I. SCOPE: Administrative Policy No. AD 2.26 Page: 1 of 5 This policy applies to all directors, officers, employees, agents, and shareholders of Tenet Healthcare Corporation, its subsidiaries and/or affiliates

More information

LANTHEUS HOLDINGS, INC. Foreign Corrupt Practices Act and Anti-Bribery Compliance Policy

LANTHEUS HOLDINGS, INC. Foreign Corrupt Practices Act and Anti-Bribery Compliance Policy LANTHEUS HOLDINGS, INC. Foreign Corrupt Practices Act and Anti-Bribery Compliance Policy 1. Introduction. Applicability. This Foreign Corrupt Practices Act and Anti-Bribery Compliance Policy (this Policy

More information

Chambers General Counsel Seminar

Chambers General Counsel Seminar Chambers General Counsel Seminar FPCA: Current Challenges for In-House Counsel Gregory Kehoe Greenberg Traurig Michael Marinelli Greenberg Traurig Ernest Edgar Atkins North America Why is FCPA Important

More information

The Foreign Corrupt Practices Act: A Primer. Mark Srere Paul Huey-Burns Anita Esslinger May 12, 2011

The Foreign Corrupt Practices Act: A Primer. Mark Srere Paul Huey-Burns Anita Esslinger May 12, 2011 The Foreign Corrupt Practices Act: A Primer Mark Srere Paul Huey-Burns Anita Esslinger May 12, 2011 Today's Presenters Anita Esslinger Paul Huey-Burns Mark Srere 2 Topics of Discussion Relevance Overview

More information

EAGLE PARENT, INC EPICOR SOFTWARE CORPORATION ACTIVANT SOLUTIONS, INC. FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY. (As Adopted - July 2011)

EAGLE PARENT, INC EPICOR SOFTWARE CORPORATION ACTIVANT SOLUTIONS, INC. FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY. (As Adopted - July 2011) EAGLE PARENT, INC EPICOR SOFTWARE CORPORATION ACTIVANT SOLUTIONS, INC. FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY (As Adopted - July 2011) 1.0 FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY ( FCPA

More information

Exhibit B SUMMIT ESP, LLC POLICY RELATED TO COMPLIANCE WITH THE UNITED STATES FOREIGN CORRUPT PRACTICES ACT

Exhibit B SUMMIT ESP, LLC POLICY RELATED TO COMPLIANCE WITH THE UNITED STATES FOREIGN CORRUPT PRACTICES ACT Exhibit B SUMMIT ESP, LLC POLICY RELATED TO COMPLIANCE WITH THE UNITED STATES FOREIGN CORRUPT PRACTICES ACT Summit ESP, LLC and any related companies (collectively Summit ) will conduct its business transactions

More information

Understanding the Foreign Corrupt Practices Act. A training program for Evergreen

Understanding the Foreign Corrupt Practices Act. A training program for Evergreen Understanding the Foreign Corrupt Practices Act A training program for Evergreen 2012 Why this is Important to know The FCPA has had a significant impact on the way American firms do business since it

More information

Anti-Corruption Enforcement and Compliance Update. Michael Volkov, Esq. Carlos Ortiz, Esq.

Anti-Corruption Enforcement and Compliance Update. Michael Volkov, Esq. Carlos Ortiz, Esq. Anti-Corruption Enforcement and Compliance Update Michael Volkov, Esq. Carlos Ortiz, Esq. November 2012 Today s presenters and some notes... Mike Volkov Washington, D.C. Carlos Ortiz Washington, D.C. Welcome.

More information

Beyond Compliance: Building a Robust Ethics and Compliance Program

Beyond Compliance: Building a Robust Ethics and Compliance Program Beyond Compliance: Building a Robust Ethics and Compliance Program Overview Risks are increasing and organizations are called to develop effective compliance risk mitigation programs Today, the explosion

More information

DOJ and SEC Release FCPA Resource Guide: What Does Your Company Do Now? January 8, 2013 By: Evelyn Suarez & Patrick Hanes

DOJ and SEC Release FCPA Resource Guide: What Does Your Company Do Now? January 8, 2013 By: Evelyn Suarez & Patrick Hanes DOJ and SEC Release FCPA Resource Guide: What Does Your Company Do Now? January 8, 2013 By: Evelyn Suarez & Patrick Hanes Speakers Evelyn M. Suarez International Law Williams Mullen, Washington D.C. esuarez@williamsmullen.com

More information

ELEPHANT TALK COMMUNICATIONS CORP. FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY

ELEPHANT TALK COMMUNICATIONS CORP. FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY ELEPHANT TALK COMMUNICATIONS CORP. FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY I. POLICY STATEMENT This Foreign Corrupt Practices Act Compliancy Policy (the Policy ) has been adopted by Elephant Talk

More information

Securities Litigation Alert The Foreign Corrupt Practices Act: The Next Corporate Scandal?

Securities Litigation Alert The Foreign Corrupt Practices Act: The Next Corporate Scandal? Securities Litigation Alert The Foreign Corrupt Practices Act: The Next Corporate Scandal? January 28, 2008 by christopher j. steskal As the stock option backdating cases wind down, what will be the next

More information

CEMEX Anti-Bribery/Anti-Corruption Global Policy

CEMEX Anti-Bribery/Anti-Corruption Global Policy CEMEX Anti-Bribery/Anti-Corruption Global Policy Last updated: December 1, 2011 TABLE OF CONTENTS I. Policy... 1 II. International Anti-Bribery Laws... 1 A. Improper Payments... 2 B. Books and Records...

More information

PEPs and the FCPA. Presented to 10 th Puerto Rican Symposium of Anti Money Laundering. February 28 March 1, 2013

PEPs and the FCPA. Presented to 10 th Puerto Rican Symposium of Anti Money Laundering. February 28 March 1, 2013 PEPs and the FCPA Presented to 10 th Puerto Rican Symposium of Anti Money Laundering February 28 March 1, 2013 by Jay Perlman, Director Global Investigations & Compliance, Navigant Table of Contents I.

More information

Foreign Corrupt Practices Act ( FCPA )

Foreign Corrupt Practices Act ( FCPA ) Foreign Corrupt Practices Act ( FCPA ) OVERVIEW The Foreign Corrupt Practices Act ( FCPA ) was passed in 1977 in an effort to address concerns over the integrity of U.S. markets after hundreds of U.S.

More information

{>> Foreign Corrupt Practices Act //]

{>> Foreign Corrupt Practices Act //] {>> Foreign Corrupt Practices Act //] FCPA Defintion FCPA Definition FOREIGN CORRUPT PRACTICES ACT - The risk of doing business abroad has just increased dramatically as non compliance with the Foreign

More information

The Foreign Corrupt Practices Act in Transactions: Plan Ahead or Pay Later

The Foreign Corrupt Practices Act in Transactions: Plan Ahead or Pay Later The Foreign Corrupt Practices Act in Transactions: Plan Ahead or Pay Later Gary DiBianco and Charles F. Smith 1 Skadden, Arps, Slate, Meagher & Flom LLP I. Introduction As U.S. based companies and foreign

More information

What Maritime Lawyers Need to Know about the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws?

What Maritime Lawyers Need to Know about the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws? What Maritime Lawyers Need to Know about the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws? Presented by Evelyn M. Suarez & Jim Barratt 2015 Port Administration & Legal Issues Seminar

More information

Overview of Recently Issued FCPA Guidance by DOJ and the SEC

Overview of Recently Issued FCPA Guidance by DOJ and the SEC Overview of Recently Issued FCPA Guidance by DOJ and the SEC George J. Terwilliger III Daniel Levin Alison Tanchyk www.morganlewis.com December 13, 2012 Presenters George J. Terwilliger III Washington,

More information

FOREIGN CORRUPT PRACTICES ACT

FOREIGN CORRUPT PRACTICES ACT ENERGY ENVIRONMENT INFRASTRUCTURE INDUSTRIAL FOREIGN CORRUPT PRACTICES ACT compliance policy Done once. Done right. ETHICS AND SAFETY HELPLINE: US/Canada Toll Free - +1-855-266-8434 Israel - +972-180-931-7129

More information

Supplier Anti-Corruption and Anti- Bribery Policy

Supplier Anti-Corruption and Anti- Bribery Policy Supplier Anti-Corruption and Anti- Bribery Policy 2014 Dwellworks Contents Purpose and Scope... 3 Core Principles... 4 Guidelines for Anti-Corruption and Anti-Bribery Compliance... 5 Applicable Definitions...

More information

Corporate Code of Conduct

Corporate Code of Conduct Corporate Code of Conduct Statement of Policy. It is the policy of Casa Mining Limited (the "Company") that all of its officers, directors, employees, contractors, consultants and agents representing the

More information

Platform Specialty Products Corporation Foreign Corrupt Practices Act/Anti-Corruption Policy

Platform Specialty Products Corporation Foreign Corrupt Practices Act/Anti-Corruption Policy 1. Introduction. Platform Specialty Products Corporation Foreign Corrupt Practices Act/Anti-Corruption Policy 1.1 Combating Corruption. Platform Specialty Products Corporation, including its subsidiaries,

More information

FOREIGN CORRUPT PRACTICES ACT

FOREIGN CORRUPT PRACTICES ACT FOREIGN CORRUPT PRACTICES ACT FAQs 1. What is the Foreign Corrupt Practices Act (FCPA)? The FCPA is a federal law, enforced by the U.S. Department of Justice, which prohibits payments, gifts, or even offers

More information

FSA reports on how banks deal with high-risk customers, correspondent banking relationships and wire transfers

FSA reports on how banks deal with high-risk customers, correspondent banking relationships and wire transfers July 2011 FSA reports on how banks deal with high-risk customers, correspondent banking relationships and wire transfers FSA reports on how banks deal with high-risk customers, correspondent banking 1

More information

Foreign Corrupt Practices Act Summary and Policy

Foreign Corrupt Practices Act Summary and Policy I. Introduction/Overview Foreign Corrupt Practices Act Summary and Policy It is the policy of Cantel Medical Corp. and its subsidiaries (the Company ) to comply with all applicable laws, rules and regulations,

More information

What You Need to Know about the U.S. Foreign Corrupt Practices Act

What You Need to Know about the U.S. Foreign Corrupt Practices Act What You Need to Know about the U.S. Foreign Corrupt Practices Act Angella Castille Faegre Baker Daniels LLP Presentation to Indiana University October 9, 2012 Overview Introduction Enforcement Trends

More information

Foreign Corrupt Practices Act & Compliance Policy

Foreign Corrupt Practices Act & Compliance Policy Team Resources Management () INTEGRITY MANAGEMENT SYSTEM (IMS) Printed documents are considered uncontrolled. Controlled documents can be found on the Atlantica server. -2-POL-057 1 0 02-Dec-2013 1 of

More information

THE FOREIGN CORRUPT PRACTICES ACT: AN OVERVIEW

THE FOREIGN CORRUPT PRACTICES ACT: AN OVERVIEW THE FOREIGN CORRUPT PRACTICES ACT: AN OVERVIEW 1 This white paper summarizes some of the key points, considerations, and factors when faced with a Foreign Corrupt Practices Act matter. As with any overview,

More information

Anti-Bribery and Corruption Policy

Anti-Bribery and Corruption Policy Newcrest strictly prohibits bribery and other unlawful or improper payments made to any individual or entity, as outlined in this Anti-Bribery & Corruption Policy. Newcrest's Anti- Bribery & Corruption

More information

ANTI-BRIBERY. Table of Contents Page #

ANTI-BRIBERY. Table of Contents Page # Responsible University Official: Vice President for Finance Operations and Treasurer Responsible Office: Office of Financial Operations Origination Date: March 31, 2015 ANTI-BRIBERY Policy Statement Northwestern

More information

LAUREATE ANTI-CORRUPTION POLICY

LAUREATE ANTI-CORRUPTION POLICY LAUREATE ANTI-CORRUPTION POLICY Laureate Anti-Corruption Policy 1.0 PURPOSE AND BACKGROUND This Anti-Corruption Policy establishes basic standards and a framework for the prevention and detection of bribery

More information

FCPA Compliance: An Ounce of Prevention.

FCPA Compliance: An Ounce of Prevention. FCPA Compliance: An Ounce of Prevention. Michael E. Burke Arnall Golden Gregory LLP Washington, DC +1.202.677.4046 Mike.Burke@agg.com Webinar Overview Today s Discussion FCPA Overview Recent Trends in

More information

FCPA Compliance: An Investigator s Perspective. By Joseph Picarello

FCPA Compliance: An Investigator s Perspective. By Joseph Picarello FCPA Compliance: An Investigator s Perspective By Joseph Picarello Agenda FCPA Overview Background Provisions What s prohibited? / What s permissible? Fines / Other Consequences UK Bribery Act Common Fraud

More information

Guidance from the FCPA Experience Building an Effective Approach to the UK Bribery Act

Guidance from the FCPA Experience Building an Effective Approach to the UK Bribery Act Guidance from the FCPA Experience Building an Effective Approach to the UK Bribery Act Presented by: Toby Vick McGuireWoods LLP 1 I. THE FCPA EXPERIENCE THE FCPA HAS BECOME A PROMINENT COMPLIANCE ISSUE

More information

Gold Resource Corporation

Gold Resource Corporation Gold Resource Corporation FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY Adopted by the Board of Directors effective December 31, 2011 1.0 Introduction The Foreign Corrupt Practices Act (FCPA) is a United

More information

FOREIGN CORRUPT PRACTICES ACT ANTIBRIBERY PROVISIONS

FOREIGN CORRUPT PRACTICES ACT ANTIBRIBERY PROVISIONS FOREIGN CORRUPT PRACTICES ACT ANTIBRIBERY PROVISIONS United States Department of Justice Fraud Section, Criminal Division 10th & Constitution Ave. NW (Bond 4th fl.) Washington, D.C. 20530 Phone: (202)

More information

Compliance with the Anti-Corruption Laws

Compliance with the Anti-Corruption Laws Corporate Headquarters Corporate Policy Statement CPS-730 Revision: 5 Effective: April 7, 2014 Copyright 2014 Lockheed Martin Corporation Current policies and procedures are on the Lockheed Martin Intranet

More information

Regulation for Compliance with Anti-Corruption Acts

Regulation for Compliance with Anti-Corruption Acts Regulation for Compliance with Anti-Corruption Acts 2014. 2. 24. Samsung Techwin Co., Ltd. Table of Contents Chapter 1 Article 1 Article 2 Article 3 General Rules Purpose Applicability Definition Chapter

More information

ANTI BRIBERY AND FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY

ANTI BRIBERY AND FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY ANTI BRIBERY AND FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY THIS POLICY DOES NOT CREATE A CONTRACT OF EMPLOYMENT OR ALTER THE AT WILL NATURE OF ANY EMPLOYEE S EMPLOYMENT IN ANY WAY. 1. Statement of

More information

The U.S. Foreign Corrupt Practice Act. John McDermott Professor of Law Loyola Law School Los Angeles

The U.S. Foreign Corrupt Practice Act. John McDermott Professor of Law Loyola Law School Los Angeles The U.S. Foreign Corrupt Practice Act John McDermott Professor of Law Loyola Law School Los Angeles The U.S FCPA and other Anti-bribery laws The US FCPA was enacted in 1977 It was prompted by the Watergate

More information

ING LEASE UK GIFTS, ENTERTAINMENT AND ANTI-BRIBERY POLICY

ING LEASE UK GIFTS, ENTERTAINMENT AND ANTI-BRIBERY POLICY ING LEASE UK GIFTS, ENTERTAINMENT AND ANTI-BRIBERY POLICY 1 CONTENTS Statement from the Board of ING Lease (UK) Limited POLICY 1. Introduction 2. Objectives 3. Scope 4. Definitions 5. Rules on Gifts and

More information

NCI BUILDING SYSTEMS, INC. FOREIGN CORRUPT PRACTICES ACT POLICY STATEMENT AND COMPLIANCE GUIDE

NCI BUILDING SYSTEMS, INC. FOREIGN CORRUPT PRACTICES ACT POLICY STATEMENT AND COMPLIANCE GUIDE NCI BUILDING SYSTEMS, INC. FOREIGN CORRUPT PRACTICES ACT POLICY STATEMENT AND COMPLIANCE GUIDE Introduction The Foreign Corrupt Practices Act as amended by the International Anti-bribery and Fair Competition

More information

Bank of New York Mellon violates FCPA. The United States Securities and Exchange Commission (SEC) announced in

Bank of New York Mellon violates FCPA. The United States Securities and Exchange Commission (SEC) announced in Bank of New York Mellon violates FCPA The United States Securities and Exchange Commission (SEC) announced in August that Bank of New York Mellon (BNY Mellon) agreed to pay USD 14.8 million (including

More information

HOWARD UNIVERSITY POLICY

HOWARD UNIVERSITY POLICY HOWARD UNIVERSITY POLICY Policy Number: 400-007 Policy Title: CONDUCTING GLOBAL BUSINESS IN COMPLIANCE WITH FOREIGN CORRUPT PRACTICES ACT Responsible Officer: General Counsel and Chief Compliance Officer

More information

The Cloud and Cross-Border Risks - Singapore

The Cloud and Cross-Border Risks - Singapore The Cloud and Cross-Border Risks - Singapore February 2011 What is the objective of the paper? Macquarie Telecom has commissioned this paper by international law firm Freshfields Bruckhaus Deringer in

More information

THE US FOREIGN CORRUPT PRACTICES ACT ( FCPA ) COMPLIANCE POLICY AND GUIDELINES

THE US FOREIGN CORRUPT PRACTICES ACT ( FCPA ) COMPLIANCE POLICY AND GUIDELINES THE US FOREIGN CORRUPT PRACTICES ACT ( FCPA ) COMPLIANCE POLICY AND GUIDELINES 1. INTRODUCTION 1.1 The purpose of this policy is to provide all employees, directors and officers of DRDGOLD Limited, its

More information

Insurance and reinsurance news

Insurance and reinsurance news Insurance and reinsurance news Insurance Mediation Directive 2 what it means for you Summary On 3 July 2012 the European Commission adopted a proposal to revise the Insurance Mediation Directive (IMD2)

More information

Course 4800: Understanding the Foreign Corrupt Practices Act - FCPA (1 day)

Course 4800: Understanding the Foreign Corrupt Practices Act - FCPA (1 day) Course 4800: Understanding the Foreign Corrupt Practices Act - FCPA (1 day) Course introduction This one-day course provides a detailed review of the anti-bribery provisions of the Foreign Corrupt Practices

More information

Freshfields Bruckhaus Deringer Changes to unfair trade practices law in Hong Kong. Summary

Freshfields Bruckhaus Deringer Changes to unfair trade practices law in Hong Kong. Summary Briefing Changes to unfair trade practices law in Hong Kong Summary Amendments to the Hong Kong Trade Descriptions Ordinance will come into force on 19. The changes broaden the application of the law to

More information

FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY

FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY Acuity Brands, Inc. is committed to maintaining the highest level of ethical and legal standards in the conduct of our business activities. The Company s

More information

What Every Business Lawyer Should Know About Anti-Corruption

What Every Business Lawyer Should Know About Anti-Corruption What Every Business Lawyer Should Know About Anti-Corruption Stephen King, MasterCard William Devaney, Baker & McKenzie, New York Marc Litt, Baker & McKenzie, New York Jonathan Peddie, Baker & McKenzie,

More information

FRANCHISORS AND FRANCHISEES: UNDERSTANDING COMPLIANCE RISKS

FRANCHISORS AND FRANCHISEES: UNDERSTANDING COMPLIANCE RISKS FRANCHISORS AND FRANCHISEES: UNDERSTANDING COMPLIANCE RISKS Franchisors and Franchisees: Understanding Compliance Risks What do KFC, Liberty Tax Service, Fatburger, and Orkin have in common? In addition

More information

The Latest Wave of Securities Enforcement Actions And What To Do About It

The Latest Wave of Securities Enforcement Actions And What To Do About It The Latest Wave of Securities Enforcement Actions And What To Do About It Robert Kent Chicago, IL 6 June 2012 Regulatory and Enforcement Environment Regulatory and Enforcement History Looking Back on a

More information

M&A in 2015: Successor Liability Under the FCPA. Norton Rose Fulbright US LLP Thursday, February 26, 2015

M&A in 2015: Successor Liability Under the FCPA. Norton Rose Fulbright US LLP Thursday, February 26, 2015 M&A in 2015: Successor Liability Under the FCPA Norton Rose Fulbright US LLP Thursday, February 26, 2015 Speaker Marsha Z. Gerber Partner Norton Rose Fulbright US LLP Marsha Gerber is a partner in the

More information

Understanding the FCPA. Charles E. Meacham Gardere Wynne Sewell LLP Phone: 713.276.5633 cmeacham@gardere.com

Understanding the FCPA. Charles E. Meacham Gardere Wynne Sewell LLP Phone: 713.276.5633 cmeacham@gardere.com Understanding the FCPA Charles E. Meacham Gardere Wynne Sewell LLP Phone: 713.276.5633 cmeacham@gardere.com Increased FCPA Enforcement Around the World Alcoa pays $384 million to resolve Bahrain-bribery

More information

OMNI TECHNICAL SOLUTIONS. Business Ethics, Compliance, Anti-Corruption and Anti-Money Laundering Policy

OMNI TECHNICAL SOLUTIONS. Business Ethics, Compliance, Anti-Corruption and Anti-Money Laundering Policy OMNI TECHNICAL SOLUTIONS Business Ethics, Compliance, Anti-Corruption and Anti-Money Laundering Policy Updated: September 2015 Table of Contents 1. Introduction... 2 2. Business Ethics... 3 2.1 Compliance...

More information

of the US Foreign Corrupt Practices

of the US Foreign Corrupt Practices The Foreign Corrupt Practices Act US legislation with global implications Dick Thornburgh, Edward J Fishman, Michael J Missal, Jeffrey B Maletta and Matt T Morley of K&L Gates LLP examine anti-corruption

More information

FOREIGN CORRUPT PRACTICES ACT AND ANTI-CORRUPTION COMPLIANCE POLICY. Adopted April 30, 2014

FOREIGN CORRUPT PRACTICES ACT AND ANTI-CORRUPTION COMPLIANCE POLICY. Adopted April 30, 2014 FOREIGN CORRUPT PRACTICES ACT AND ANTI-CORRUPTION COMPLIANCE POLICY Adopted April 30, 2014 134782_1 TABLE OF CONTENTS I. POLICY STATEMENT... 1 II. KEY TERMS... 2 III. SCOPE AND APPLICABILITY OF THIS POLICY...

More information

ERIN ENERGY CORPORATION. ANTI-CORRUPTION COMPLIANCE POLICY Effective Date: 10/1/2011

ERIN ENERGY CORPORATION. ANTI-CORRUPTION COMPLIANCE POLICY Effective Date: 10/1/2011 ERIN ENERGY CORPORATION ANTI-CORRUPTION COMPLIANCE POLICY Effective Date: 10/1/2011 Statement of Policy It is the policy of Erin Energy Corporation, (the Company ) to conduct its worldwide operations ethically

More information

FCPA: Handling Increased Global Anti-Corruption Enforcement

FCPA: Handling Increased Global Anti-Corruption Enforcement FCPA: Handling Increased Global Anti-Corruption Enforcement Allison Hoffman, Incisive Media David Krakoff, Mayer Brown LLP Claudius Sokenu, Mayer Brown LLP David Wilkins, The Dow Chemical Company Mayer

More information

CHARTER FOR THE THE REGULATORY, COMPLIANCE & GOVERNMENT AFFAIRS COMMITTEE CHARTER THE BOARD OF DIRECTORS

CHARTER FOR THE THE REGULATORY, COMPLIANCE & GOVERNMENT AFFAIRS COMMITTEE CHARTER THE BOARD OF DIRECTORS CHARTER FOR THE THE REGULATORY, COMPLIANCE & GOVERNMENT AFFAIRS COMMITTEE CHARTER OF THE BOARD OF DIRECTORS OF Copyright/permission to reproduce Materials in this document were produced or compiled by

More information