Anti-Bribery and Anti-Corruption
We prohibit all forms of bribery, corruption, improper payments or laundering the corrupt proceeds of these practices.
Employees are expected to operate ethically, honestly and with integrity, and to comply with federal, state and local laws.
It's Up to Us
- • Contact the State & Federal Affairs Department for approval before giving a gift to a public official, regardless of whether personal funds will be used and regardless of the value of the gift.
- • Understand how to recognize bribes and report any requests for improper payments to the Legal Department immediately.
- • Work with ATC’s State & Federal Affairs department before arranging meetings with Public Officials.
- • Raise any concerns with the Legal Department or Audit, Risk Management and Compliance if there are any concerns or warning signs about any third-party business partner.
- • Record all transactions and payments accurately and honestly.
Sometimes There Are Grey Areas
These explanations help shed some light.
Accordion
Most people consider bribes to be cash payments in exchange for business. But bribes can come in many different forms, including providing anything of value to an individual in exchange for a business or personal advantage. They can be disguised as equipment, travel, discounts, personal use of ATC property, sponsorships, apprenticeships, charitable donations and even job offers.
A type of bribe including anything of value (money, goods or services) that is given for improper purposes to someone in return for an advantage in a business arrangement. Kickbacks are usually arranged in advance as part of the business transaction.
While anti-corruption laws apply broadly, they are especially strict about offering or giving anything improper to a public official. The term “public official” can include a wide range of people beyond elected officials or those with government functions, including elected officials, appointed officials or honorary public officials, or employee of:
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A Federal, State or local unit of government in the United States
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An Indian Tribe
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A national or State political party or associated organization, including a candidate for public office
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A national, regional or local unit of any foreign government, or group of governments acting together as an international organization
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A person acting in an official capacity for a government agency, quasi-governmental entities, department or instrumentality or a public organization
Even the spouses, family members and close friends of the examples above could be “public officials” under anti-bribery laws.
Understanding the Consequences
Flip Cards
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Violating these laws can come at a heavy price. Organizations and individuals can face fines, lost business, and even criminal charges in some cases. If it even looks like we pay or accept bribes or kickbacks, our reputation could suffer, and we could lose the trust of our customers and business partners.