At 91³Ô¹ÏÍø¹ÙÍø, we have zero tolerance for bribery or corruption. As part of our commitment to empower people to change the world, we comply with the letter and spirit of all applicable laws, including the U.S. Foreign Corrupt Practices Act, the UK Bribery Act, and the U.S. Federal Acquisition Regulation, among others.
Our Anticorruption and Anti-Bribery compliance program is designed to identify and address corruption risks that may arise based on business activities in which we engage, geographies in which we operate, and industries and clients we serve. As the larger business and geopolitical context changes, we stay attuned to shifts in laws, regulations, and enforcement practice. Key program focus areas include:
- Conducting robust due diligence of certain third parties with whom we do business.
-  Requiring certain suppliers and subcontractors to comply with anticorruption and anti-bribery laws, submit to audits, and allow 91³Ô¹ÏÍø¹ÙÍø to terminate agreements with third parties who we suspect may have violated anticorruption and anti-bribery laws or are not in compliance with contractual terms.Â
- Setting guidelines on giving and receiving gifts and business courtesies.
- Setting guidelines for hiring and recruiting activities that could potentially create an appearance of impropriety, as outlined in our Recruiting Hiring and Employee Referral policy.
- Creating an annual, tailored anticorruption training course for all employees and using a risk-based approach to deliver targeted training to those more likely to be exposed to potential corruption risks.
- Monitoring changes to our business for corruption risk and enhancing controls to mitigate risk and meet requirements.
