For companies doing business abroad, comprehensive training programs for employees and contractors is the most effective way to avoid violating a federal law making it illegal to bribe foreign officials, experts on the law said at a recent State Bar of Georgia symposium in Atlanta.
The Foreign Corrupt Practices Act can extend to a company’s agent or contractors in another country, even if executives in the U.S. were unaware of the bribes.
“You want to make sure you have a comprehensive set of documents and policies to support the range of conduct that would be covered by the Foreign Corrupt Practices Act,” Nisa Gosselink-Ulep, an attorney in the Washington office of Paul Hastings, Janofsky & Walker LLP, told symposium participants.
Companies should consider developing a how-to-guide for employees that would break down the law’s complexities, she added.
“Say I work for your office somewhere in Africa,” she said. “I may know about the Foreign Corrupt Practices Act and I may be able to say, ‘Oh, I’m not supposed to bribe.’ But what does that really mean?”
via Foreign Corrupt Practices Act: Employee Training Crucial.