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Bio-Rad iCode Introduction.mp4
Anti-Corruption Compliance
We do not bribe or engage in any corrupt activity.
We always exhibit integrity in dealing with customers and business partners. We know that there are many international anti-corruption laws, some carrying significant penalties, that apply to our interactions with government officials anywhere in the world, including U.S. federal and state officials, and with commercial business partners, including suppliers.
Put simply, we do not bribe nor do we ever solicit or accept any bribes. This includes small payments that low-level government agents request to expedite or facilitate routine government actions, such as issuing permits. These small payments are often called “facilitating payments” or “grease payments,” and we do not make them.
We are also careful to make sure that no third party offers a bribe or attempts to bribe another on Bio-Rad’s behalf, as we could be held responsible for that third party’s conduct. It is for this reason that we do not hire business partners to undertake actions that we would not do ourselves, and we make sure our business partners are qualified and that they strictly adhere to the law and our policies.
It is important that we do not misrepresent any payments in our books and records. If you are aware of payments – including facilitating payments – that may be mischaracterized in our records, immediately contact the Compliance Department.
A bribe can include anything of value given with the intent of improperly influencing the decision-making of another in order to gain or retain business. Bribes can be in cash, goods, products, free services, or gifts.
Expectations
- We neither make nor accept bribes.
- We do not make facilitating payments.
- We carefully select our business partners and any third parties acting on our behalf, and we monitor their behavior moving forward.
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Key Terms
Anyone who works for or otherwise represents a government, a government department, or a government-controlled or government-owned organization. For example, a doctor who works in a state-owned hospital would be considered a government official. This term also includes politicians or employees of a public international organization such as the United Nations.
Anything of value provided as a reward for improperly influencing an official decision for business advantage, such as rewarding a purchasing agent for awarding work to a preferred vendor.
Anything that has value, including cash, cash equivalents (such as gift cards), gifts, free services, job opportunities, charitable contributions, political contributions, travel expenses, and entertainment.
FAQs
A: No. We must be careful when we provide anything of value, including travel and accommodations, to potential clients and other business partners. We never provide travel for family members. In this case, it is possible that the purchasing manager is a government official, since hospitals can be state-owned. Before you agree to such expenses, particularly in the case of government officials, you must discuss the situation with the Compliance Department and get approval.
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A:
- We are doing business in a country that has a reputation for corruption.
- A Bio-Rad agent or subcontractor asks for an unusually large or contingent fee.
- We are asked to make payment to another person, in another country, or to a numbered bank account, or to pay in cash.
- A Bio-Rad agent has a family or business relationship with a public official.
- A healthcare entity asks us to make a political or charitable contribution or to use a particular subcontractor.
- A Bio-Rad agent asks for an increase in the agreed-upon fees to close the deal.
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A: You may accept lunch invitations if you are meeting for a business purpose, but frequent or extravagant meals can appear to create a conflict of interest. Consult your supervisor. Tell the provider about our Code and limit hospitality in a reasonable manner.
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