Foreign Corrupt Practices Act (FCPA) Training

About the Training

SAIC has policies and procedures to ensure compliance with the Foreign Corrupt Practices Act. The Act criminalizes acts of bribery in pursuit of international business or the provision of anything of value in order to obtain an unfair advantage. In particular, SAIC procedures regulate the hiring of international sales representatives as reflected in the SAIC Administrative Handbook. Information regarding these policies and procedures, including an FCPA training presentation, is provided through the link below for employees without access to ISSAIC.

SAIC has put policies and procedures in place with regard to hiring international sales representatives as reflected in the SAIC Administrative Handbook. These policies and procedures are important, because hiring a sales representative without following company procedures can create liability for both the company and the employees involved under the U.S. Foreign Corrupt Practices Act ("FCPA").

Who Should Take the Training?

All U.S. or foreign national employees, consultants or agents that are or become involved in obtaining or retaining international business for SAIC are required to view this FCPA training presentation. This includes:

• Line managers
• Business development
• Finance and contracts personnel
• Any other persons in SAIC overseeing or developing international business

Why You Should Take The Training

The FCPA criminalizes bribery as a means of getting business overseas or obtaining an unfair advantage. It also imposes civil liability on companies that do not accurately record all expenditures and transactions in their accounts. The scope of the FCPA is very broad: it is a crime for a U.S. company, its officers, employees, agents, etc. to promise to pay or pay, promise to give or give, or authorize the paying or giving of anything of value, directly or indirectly, to foreign government officials in order to influence the official's acts or decisions, or to induce the official to influence others to affect the acts or decisions of a foreign government or international organization, if this is done in order to obtain or retain business or an unfair advantage. The term "foreign government official" includes anyone acting in an official capacity, employees of state-owned enterprises, officials of public international organizations, candidates for public office, and officials of political parties.

The FCPA has both criminal and civil aspects and is aggressively enforced by the U.S. Department of Justice and the Securities and Exchange Commission. Both companies and individual employees can be prosecuted. Mere indictment under the FCPA may trigger sanctions, including loss of export privileges and debarment from federal contracts. Individuals can be fined up to $100,000 for each violation and imprisoned for up to five years, or both. Fines assessed against individuals cannot be reimbursed by the company.

Additional Information

• "Live" training and other information on the FCPA are also available from Corporate Legal. Please contact Marty Waters for more information.
• If you have any questions about the FCPA or suspect a violation, contact Corporate Legal immediately.
• Administrative Handbook Policy A-27, Complying with the Foreign Corrupt Practice Act (FCPA)