FCPA Guidance-Office of the General Counsel - Carnegie Mellon University

FCPA Guidance

Carnegie Mellon University expects all members of the University community to maintain the highest ethical and professional conduct in all domains.  Conducting ourselves in accordance with the highest ethical, legal, and professional standards is not only consistent with the University’s mission but also reflects the University’s values and ensures that members of the University community strive for excellence in all aspects of their work. 

Simply put, the University does not allow bribes, kickbacks, payments, or any other similar inducements to be offered or given directly to any individual or organization – or given indirectly through any intermediary such as an attorney, agent, consultant, or other third-party individual or organization – for any purpose, including for the purpose of influencing such individual or organization in connection with obtaining or retaining business for, or directing business to, the University or a member of the University community, or for the purpose of securing an otherwise improper advantage for the University or any member of the University community.  The University’s activities in foreign countries are no exception.  Furthermore, they are subject to particular scrutiny.

This guidance has been compiled by the Office of General Counsel to assist members of the University community to recognize FCPA issues and to avoid circumstances which may lead to or give the appearance of unethical business conduct by members of the University community.

Scope of this Guidance

Summary of the FCPA

Due Dilligence

Permissible Payments and Affirmative Defenses

Specific Guidance

Charitable Donations

Third Parties