This is a corporate policy document designed to meet the standards of the Foreign Corrupt Practices Act, a provision of the Securities and Exchange Act of 1934. FCPA generally prohibits payments by companies and their representatives to foreign (i.e., non-U.S.) government and quasi-government officials to secure business.
The Hennepin Minnesota Foreign Corrupt Practices Act (CPA) — Corporate Policy is a set of guidelines and regulations implemented by companies operating in Hennepin County, Minnesota to ensure compliance with the U.S. Foreign Corrupt Practices Act. The CPA is a federal law that prohibits bribery and corrupt practices by U.S. companies or individuals working for them, both domestically and internationally. This policy is specifically designed to address the CPA requirements and needs of businesses located in Hennepin County, Minnesota. Key terms relevant to this policy include: 1. Hennepin County: Hennepin County is the most populous county in Minnesota, encompassing the city of Minneapolis and several other cities. It is a hub for various industries, including finance, technology, healthcare, and manufacturing. 2. Foreign Corrupt Practices Act (CPA): The CPA is a U.S. federal law enacted in 1977 to combat corruption and bribery in international business transactions. It consists of two main provisions: the anti-bribery provisions and the accounting provisions. 3. Corporate Policy: The corporate policy is a comprehensive set of guidelines and procedures that aim to ensure ethical conduct, integrity, and compliance within an organization. It helps companies navigate legal and ethical challenges and establishes a framework to prevent foreign corrupt practices. Types of Hennepin Minnesota Foreign Corrupt Practices Act — Corporate Policies: 1CPAPA Compliance Policy: This policy outlines the company's commitment to adhering to the CPA regulations and specifies the steps employees must take to ensure compliance. It covers areas such as gifts, entertainment, and donations, third-party due diligence, accounting practices, and training. 2. Anti-Bribery Policy: This policy focuses specifically on preventing bribery and corrupt practices in business transactions. It establishes guidelines for employees, agents, and business partners, detailing the types of transactions that are strictly prohibited and the consequences for non-compliance. 3. Third-Party Due Diligence Policy: This policy emphasizes the importance of conducting thorough due diligence on third parties, such as consultants, agents, and distributors, to mitigate potential risks of corruption and bribery. It outlines the process of vetting and monitoring third-party relationships. 4. Accounting and Record keeping Policy: This policy ensures accurate and transparent financial reporting and record keeping practices. It aligns with the CPA's accounting provisions, which require companies to keep detailed and accurate records to ensure transparency and prevent illicit activities. Companies operating in Hennepin County, Minnesota, recognize the significance of implementing comprehensive and tailored FCPA-Corporate Policies to protect their reputation, ensure lawful operations, and contribute to a fair and ethical business environment.The Hennepin Minnesota Foreign Corrupt Practices Act (CPA) — Corporate Policy is a set of guidelines and regulations implemented by companies operating in Hennepin County, Minnesota to ensure compliance with the U.S. Foreign Corrupt Practices Act. The CPA is a federal law that prohibits bribery and corrupt practices by U.S. companies or individuals working for them, both domestically and internationally. This policy is specifically designed to address the CPA requirements and needs of businesses located in Hennepin County, Minnesota. Key terms relevant to this policy include: 1. Hennepin County: Hennepin County is the most populous county in Minnesota, encompassing the city of Minneapolis and several other cities. It is a hub for various industries, including finance, technology, healthcare, and manufacturing. 2. Foreign Corrupt Practices Act (CPA): The CPA is a U.S. federal law enacted in 1977 to combat corruption and bribery in international business transactions. It consists of two main provisions: the anti-bribery provisions and the accounting provisions. 3. Corporate Policy: The corporate policy is a comprehensive set of guidelines and procedures that aim to ensure ethical conduct, integrity, and compliance within an organization. It helps companies navigate legal and ethical challenges and establishes a framework to prevent foreign corrupt practices. Types of Hennepin Minnesota Foreign Corrupt Practices Act — Corporate Policies: 1CPAPA Compliance Policy: This policy outlines the company's commitment to adhering to the CPA regulations and specifies the steps employees must take to ensure compliance. It covers areas such as gifts, entertainment, and donations, third-party due diligence, accounting practices, and training. 2. Anti-Bribery Policy: This policy focuses specifically on preventing bribery and corrupt practices in business transactions. It establishes guidelines for employees, agents, and business partners, detailing the types of transactions that are strictly prohibited and the consequences for non-compliance. 3. Third-Party Due Diligence Policy: This policy emphasizes the importance of conducting thorough due diligence on third parties, such as consultants, agents, and distributors, to mitigate potential risks of corruption and bribery. It outlines the process of vetting and monitoring third-party relationships. 4. Accounting and Record keeping Policy: This policy ensures accurate and transparent financial reporting and record keeping practices. It aligns with the CPA's accounting provisions, which require companies to keep detailed and accurate records to ensure transparency and prevent illicit activities. Companies operating in Hennepin County, Minnesota, recognize the significance of implementing comprehensive and tailored FCPA-Corporate Policies to protect their reputation, ensure lawful operations, and contribute to a fair and ethical business environment.
Para su conveniencia, debajo del texto en español le brindamos la versión completa de este formulario en inglés. For your convenience, the complete English version of this form is attached below the Spanish version.
