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 New Hampshire Foreign Corrupt Practices Act (NHF CPA) is a corporate policy that aims to prevent bribery and corrupt business practices by companies operating in international markets. The act is based on the federal Foreign Corrupt Practices Act (CPA), but tailored specifically for companies incorporated or having a principal place of business in the state of New Hampshire. The NHF CPA provides guidelines for companies to ensure compliance with anti-bribery laws and regulations, promoting fair and ethical business conduct worldwide. Under the NHF CPA, companies are required to implement robust internal controls, policies, and procedures to detect and prevent corrupt practices. These policies outline the standards of conduct expected from employees, agents, consultants, and business partners engaged in international dealings on behalf of the company. By having a comprehensive corporate policy in place, companies can mitigate the risk of legal penalties, reputation damage, and financial losses resulting from violations of anti-corruption laws. The NHF CPA corporate policy encompasses various key elements, including: 1. Prohibition of Bribery: The policy expressly prohibits the offering, giving, accepting, or soliciting of bribes, kickbacks, or any other form of improper payment to foreign officials, political parties, candidates, or any other individual or entity. 2. Due Diligence: The policy emphasizes the importance of conducting thorough due diligence on business partners, agents, and consultants to ensure they have a reputation for ethical business practices, are not affiliated with corrupt practices, and adhere to applicable anti-corruption laws. 3. Gifts, Entertainment, and Hospitality: The policy provides guidelines on acceptable practices when offering or receiving gifts, entertainment, or hospitality to avoid creating a perception of bribery or impropriety. 4. Record-Keeping and Accounting: The policy requires accurate and transparent books, records, and accounts that reflect all transactions in accordance with generally accepted accounting principles. It prohibits the creation of off-the-books accounts or falsification of records. 5. Training and Awareness: The policy mandates regular training programs to educate employees on the NHF CPA requirements, potential risks, and best practices for compliance. It also encourages open dialogue and reporting of any potential violations or concerns. It's important to note that there are no specific sub-types or variations of the New Hampshire Foreign Corrupt Practices Act — Corporate Policy. However, different companies may customize the policy based on their specific needs, industry regulations, and risk assessments.
