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 Georgia Foreign Corrupt Practices Act (CPA) — Corporate Policy is a set of guidelines and regulations that companies operating in Georgia must follow to prevent and mitigate corruption and bribery in international business transactions. The CPA is aimed at regulating the conduct of both U.S. and foreign companies to ensure fair practices, transparency, and ethical behavior. The CPA — Corporate Policy serves as a framework that outlines the requirements and expectations for companies to comply with anti-corruption laws. It helps organizations understand their obligations and implement adequate systems and controls to prevent bribery and corrupt practices when conducting business in Georgia. Under the Georgia CPA — Corporate Policy, there are different types or components that companies should consider. These include: 1. Anti-Bribery Provisions: This section outlines the rules and regulations prohibiting bribery of foreign officials. It prohibits offering, promising, or giving anything of value to influence an official or secure an improper business advantage in Georgia. 2. Accounting Provisions: The CPA's accounting provisions require companies to maintain accurate and transparent records that reflect their financial transactions. Companies must keep books and records that accurately and fairly represent their financial position and transactions and implement internal controls to safeguard against fraudulent practices. 3. Compliance Program: The CPA — Corporate Policy encourages companies to establish a robust compliance program to prevent and detect corrupt practices. The program should include policies, procedures, and training that educate employees on the CPA requirements and provide mechanisms for reporting any questionable activity. 4. Due Diligence: Companies are expected to conduct due diligence before entering into relationships with third parties, such as suppliers, agents, or business partners. This involves assessing the background, reputation, and integrity of the third parties to ensure they adhere to anti-corruption laws and do not pose a risk to the company. 5. Internal Controls: The CPA — Corporate Policy emphasizes the importance of implementing effective internal controls to prevent and detect corrupt practices. Companies should establish checks and balances within their financial and operational systems to identify and address potential risks. 6. Reporting and Internal Investigations: The policy emphasizes the need for companies to promptly report any suspicions or violations of the CPA. It encourages companies to establish mechanisms for confidential reporting, protects employees who report misconduct, and ensures thorough internal investigations are conducted to address allegations of corruption or bribery. By adhering to the Georgia CPA — Corporate Policy, companies can safeguard their reputation, foster fair competition, promote ethical business practices, and contribute to Georgia's efforts in combating corruption. Compliance with these regulations will help companies gain the trust of stakeholders, including customers, investors, and the public, and strengthen their competitiveness in the global market.
