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DEPARTMENT: Director's Office (Administration)


Policy Statement

All Center employees and agents conducting activities for or on behalf of the Center shall comply with the Foreign Corrupt Practices Act of 1977, or FCPA, and related anti-corruption requirements. The bribing of foreign officials and any other acts made in violation of the FCPA are prohibited. All employees and agents conducting activities for or on behalf of the Center are required to complete FCPA training if they are engaged in activities involving contact and collaborations with foreign government officials. Employees and agents who violate this policy may be subject to disciplinary action up to and including discharge from employment.

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Background/Reason for Policy

The Foreign Corrupt Practices Act of 1977 ("the FCPA" or "the Act") requires that United States corporations and individuals conducting business in foreign countries refrain from making corrupt payments to foreign officials in order to obtain or retain a business advantage.

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FCPA training will be conducted by the Center in consultation with the General Counsel.

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Foreign Corrupt Practices Act of 1977

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General Counsel, 206.667.6458

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Responsible Official: (Vice President or Senior Vice President)
Dr. Gary Gilliland, Center president and director

Manager Responsible for Policy:

Douglas Shaeffer, vice president, General Counsel

Approval Date (this Version):
March 2014

Next Review Due:
March 2017

Revision/Review Dates:

Original Approval Date:
March 2014

This version reviewed and approved by specialty committee or specialty individual:


Date Reviewed