Foreign Corrupt Practices Act Compliance Certification
(Employees)

Summary

This Foreign Corrupt Practices Act (FCPA) compliance certification template may be used for company employees to provide annual written confirmation that they are familiar with and understand the FCPA, the employer's ethics code and policies, and their current and ongoing compliance with the law. This template includes practical guidance and drafting notes. A standard best practice used by companies in managing their anti-bribery compliance programs is to obtain written certificates from all relevant personnel regarding compliance with anti-bribery laws and company policies that apply to their engagements. Accordingly, a company's decision to follow this practice will be a favorable factor when regulators assess the effectiveness of a company's anti-bribery compliance program under the FCPA and any other applicable anti-bribery laws. This certificate can be used in conjunction with a broad range of commercial agreements used by companies to engage third parties. Drafters should modify the language in this template, as necessary, to address the specific types and level of risks for each engagement. For more information on the FCPA, see Foreign Corrupt Practices Act (FCPA), Foreign Corrupt Practices Act (FCPA) Policy and Foreign Corrupt Practices Act (FCPA) Due Diligence Checklist.