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.
Miami-Dade Florida Foreign Corrupt Practices Act (CPA) — Corporate Policy is a comprehensive set of guidelines and procedures established by companies operating in Miami-Dade County, Florida, to ensure compliance with the CPA. The CPA is a federal law enacted by the United States to prohibit companies from engaging in bribery and corrupt practices in their international business dealings. Miami-Dade County, being a significant hub for international trade and business, recognizes the importance of upholding ethical standards and promoting fair business practices. The Miami-Dade Florida CPA — Corporate Policy serves to reinforce these values and assist companies in operating with transparency, integrity, and compliance with the law. The policy outlines the key provisions of the CPA and provides specific guidance on how companies should conduct themselves when dealing with foreign government officials, political parties, and candidates. It emphasizes the prohibition of bribery, gifts, favors, or any other form of corrupt payments to obtain or retain business advantages. Under the Miami-Dade Florida CPA — Corporate Policy, companies are required to implement a robust system of internal controls and compliance measures. These measures include: 1. Clear code of conduct: The policy advises companies to establish a code of conduct that outlines the ethical standards expected of employees while conducting international business transactions. It serves as a guiding document for their actions and behavior. 2. Anti-bribery and corruption training: Companies are encouraged to provide training programs to educate employees about the prohibitions imposed by the CPA and how to identify and address potential corruption risks. 3. Due diligence: The policy emphasizes the importance of conducting due diligence on third-party agents, consultants, and business partners before engaging in any business relationship. This helps ensure that the company is not inadvertently associating with individuals or organizations involved in corrupt practices. 4. Record-keeping and financial controls: The policy instructs companies to maintain accurate and detailed records of all transactions and financial activities related to their international business dealings. This includes keeping receipts, invoices, contracts, and other relevant documentation. 5. Reporting and whistleblower protection: The policy includes provisions for employees to report any suspicious or potentially corrupt activities. It assures them protection against retaliation for reporting such incidents in good faith. Different types or variations of the Miami-Dade Florida Foreign Corrupt Practices Act — Corporate Policy may exist depending on the specific industry or company size. However, the core principles and objectives to comply with the CPA remain consistent across all variations. It is crucial for companies to tailor the policy to their specific needs and ensure ongoing monitoring and enforcement to ensure compliance with both the policy and the law. By implementing and adhering to the Miami-Dade Florida CPA — Corporate Policy, companies can demonstrate their commitment to conducting business ethically, safeguarding their reputation, and avoiding legal consequences associated with foreign corrupt practices. This policy acts as a critical tool in establishing a culture of compliance and integrity within the business community of Miami-Dade County, Florida.
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.
