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ANTICORROSION POLICY May 2012 Policy: Issued by: Anticorruption Policy Ethics Compliance Committee Date: 1 May 2012 Supersedes: February 2010 ANTICORROSION POLICY INTRODUCTION/OVERVIEW Technicolor
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How to fill out the Foreign Corrupt Practices Act:

01
Familiarize yourself with the provisions of the Foreign Corrupt Practices Act (FCPA). The FCPA is a U.S. law that prohibits bribery of foreign officials and requires certain accounting and transparency measures.
02
Understand the jurisdiction of the FCPA. The FCPA applies to any U.S. company, individual, or foreign company that has a connection to the United States, including subsidiaries of U.S. companies and issuers of securities on U.S. stock exchanges.
03
Conduct a risk assessment. Evaluate your company's operations, business partners, and potential exposure to bribery and corruption risks in foreign countries. Identify high-risk areas where the FCPA may be applicable.
04
Develop a comprehensive anti-corruption compliance program. Implement policies and procedures to prevent bribery and corruption, including clear guidelines on gifts, entertainment, and other business courtesies, third-party due diligence, and accurate record-keeping.
05
Provide FCPA training to employees and business partners. Ensure that everyone understands their obligations under the FCPA and the consequences of non-compliance.
06
Establish internal controls and financial reporting systems. Implement measures that detect and prevent improper payments, such as regular audits, strong accounting practices, and transparent financial reporting.
07
Monitor and enforce compliance. Regularly review your compliance program, conduct audits, and investigate any potential violations. Take appropriate disciplinary action if necessary.
08
Maintain accurate records and documentation. Keep detailed records of all financial transactions and business dealings to demonstrate compliance with the FCPA.
09
Stay updated on FCPA developments. Monitor regulatory changes, case law, and enforcement actions to ensure that your compliance program remains effective and up to date.

Who needs the Foreign Corrupt Practices Act:

01
U.S. companies operating internationally: Any U.S. company involved in international business, including sales, investments, and operations, is subject to the FCPA.
02
Foreign companies with U.S. ties: Foreign companies that have a connection to the U.S., such as subsidiaries of U.S. companies or issuers of securities on U.S. stock exchanges, are also subject to the FCPA.
03
Individuals: The FCPA applies to individuals, including executives, employees, and agents of U.S. companies or foreign companies with U.S. ties, who engage in bribery or corruption of foreign officials.
04
Business partners and intermediaries: Any person or entity that acts on behalf of a U.S. company or foreign company with U.S. ties, including agents, distributors, consultants, and joint venture partners, can also be liable for FCPA violations.
05
Foreign officials: The FCPA prohibits the bribery of foreign officials by U.S. companies or individuals, regardless of the foreign official's rank or position.
06
Investors and shareholders: The FCPA helps protect the investments and interests of investors and shareholders by promoting transparency, fair competition, and ethical business practices.
07
Society as a whole: The FCPA aims to combat corruption, promote economic development, and ensure a level playing field for businesses around the world. By preventing bribery and corruption, it contributes to a more just and fair global business environment.
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The Foreign Corrupt Practices Act (FCPA) is a United States law that prohibits U.S. companies and individuals from bribing foreign government officials for business purposes.
Any U.S. company or individual that conducts business internationally and interacts with foreign government officials is required to comply with the FCPA.
To fill out the FCPA, companies and individuals must ensure accurate record-keeping, conduct thorough due diligence on third-party partners, provide comprehensive training to employees, and maintain a robust compliance program.
The purpose of the FCPA is to prevent bribery and corruption in international business transactions, promote transparency, and maintain a level playing field for companies operating globally.
Companies must report any payments or gifts made to foreign government officials, as well as details of any accounting irregularities or violations of the FCPA.
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