Foreign Corrupt Practices Act Policy
To: All Faculty, Staff, and Other Academic Appointees
From: Daniel Diermeier, Provost, David B. Fithian, Executive Vice President, and Kim Taylor, VP and General Counsel
Subject: Foreign Corrupt Practices Act Policy
Date: July 5, 2016
As you know, the University of Chicago’s global presence and reach has expanded significantly in recent years, and University faculty, staff and students continue to explore new opportunities to collaborate with and engage our global community. When conducting international activities, University community members are required to act ethically, honestly and with integrity and to comply with applicable laws. This includes compliance with anti-bribery provisions of the U.S. Foreign Corrupt Practices Act (“FCPA”), which prohibits bribery of foreign officials.
In order to assist University members with satisfying their broad FCPA obligations, the Office of Legal Counsel, in consultation with representatives from across the University, including Finance & Administration, the Global Engagement Office, the Office of the Provost, and University Research Administration, has developed a University-wide FCPA Policy. This new policy took effect July 1, 2016, and is available, together with additional guidance and FAQs, at https://global.uchicago.edu/us-foreign-corrupt-practices-act-fcpa-policy.
To help support this important initiative, the University will be offering trainings on the FCPA Policy throughout the year. Please contact Carmen Suen in the Global Engagement Office at 773.834.8453 should you or your department wish to request a training session. Individuals working on University programs with an international component will receive additional information from the Global Engagement Office regarding training sessions.
If you have additional questions about the FCPA Policy, please contact Russ Herron, Sr. Associate General Counsel, or Smita Singh, Assistant General Counsel, in the Office of Legal Counsel at 773.702.7237. Any known or suspected violations of the FCPA Policy must be reported to the Hotline (800-971-4317 within the U.S.; 770-776-5641 outside the U.S.) or the Office of Legal Counsel.
Policy and Administration