Overview
The Foreign Corrupt Practices Act ("FCPA") prohibits domestic corporations (including their foreign subsidiaries and affiliations) from offering, paying, or promising to pay any foreign official, political party, or political candidate for the purpose of influencing, obtaining, or retaining business. To ensure compliance with the FCPA, Staff shall be guided by the following principles:
- No gifts, other than those of nominal value, shall be given to any government official without the approval of the Foundation's President.
- Expenditures for meals, entertainment, and other normal social amenities for foreign governmental officials shall not be extravagant according to the laws and customs of the host country.
- Travel and related expenditures may be reimbursed to foreign officials only in connection with Foundation-related business and in accordance with applicable law.
- No gratuities should be paid to foreign government officials unless the payment is consistent with the Foundation's policies, permitted under local law, commensurate with the legitimate and generally accepted local customs for such expenses, and approved by the Foundation's President in advance.
Any questions regarding this policy should be directed to the Vice President, General Counsel, and Secretary of the Foundation.
