4.1 - Anti-Bribery and Corruption Policy

: Business Office
: 09/20/2018
: 09/20/2018
: 09/20/2019
Comment on Policy

4.1.1 - AUDIENCE

All University officers, employees, volunteers, contractors, agents, and other third-parties who act on behalf of Thomas More University.


The purpose of this Policy is to comply with requirements of the Federal Foreign Corrupt Practices Act.


Anything of Value: includes not only cash or cash equivalents, but also trips and airfare upgrades, entertainment, donations, investment opportunities other than arm’s length transactions for fair market value, an interest in a business venture, services, payment of medical, educational or living expenses, and transfer of information.  The determination is not the retail value, but whether the recipient subjectively attaches value to the inducement.

Bribery: the offering of money, favors or other incentives to someone in a position of trust in order to induce or obtain preferential treatment or an unfair advantage.  Guidance and additional information on the Foreign Corrupt Practices Act can be found at the U.S. Department of Justice website: http://www.justice.gov/criminal/fraud/fcpa/

Foreign Official: means any official or employee of a foreign government, or any department, agency, or instrumentality thereof, or any public international organization, and includes agents acting in an official capacity for or on behalf of any such government, department, agency, or instrumentality, or public international organization.

4.1.4 - THE POLICY

Thomas More University prohibits anyone acting on its behalf to make any payments or provide anything of value to any person, including any foreign official, directly or indirectly, for the purpose of influencing an action or decision, inducing the person to do or refrain from doing any act, or securing an unfair advantage.  This Policy applies to informal interactions as well as formal agreements.

Any contracts with or involving Foreign Officials must be in writing and reviewed by the Chief Financial Officer prior to execution of any such contract.  Specific contract language and provisions are required by the University to address compliance with the Foreign Corrupt Practices Act and this Policy, including for contracts with third parties engaged by the University to represent its interests in another country.

Violations of this Policy will result in the University taking appropriate disciplinary action against the violator, up to and including discharge from employment with the University.  Disciplinary action will be taken in accordance with the College’s policies and procedures that apply to the violator.  Conduct that violates this University also may result in civil or criminal charges and penalties against the violator in accordance with The Foreign Corrupt Practices Act.


Foreign Corrupt Practices Act

Business Ethics and Conduct Policy
Whistleblower Policy


All University officers, employees, volunteers, contractors, agents, and other third-parties who act on behalf of Thomas More University must report any concerns with respect to this Policy to an immediate supervisor or the Director of Human Resources.  In addition, individuals may also make a report by following the procedures set forth in the University’s Whistleblower Policy.

Those who report violations in good faith and in an appropriate manner, whether or not further investigation substantiates the claim, will be free from retaliation in any form.  The identity of the reporter will be protected, within legal limits, and those who retaliate against them will be disciplined.  All reported violations will be investigated promptly.


4.1.8 - HISTORY

This is a new policy.

4.1.9 - APPENDIX

There are no appendices to this Policy.

4.1.10 - APPROVALS

Laura Custer, Director of Human Resources

Rob Munson, Chief Financial Officer

Dr. Kathleen Jagger, Acting President