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Anti-Corruption Compliance
As a U.S.-based corporation, UPS, its employees, and its representatives,
are subject to the U.S. anti-bribery laws that are enforceable worldwide
and cover all UPS operations, including all businesses, joint ventures,
agents, and third-party representatives (such as independent contractors,
general sales agents, customs brokers, immigration agents, and tax
agents, among others). Anti-bribery laws include the U.S. Foreign
Corrupt Practices Act (FCPA) and all such laws of the countries in which
we operate.
Broadly speaking, the FCPA and other anti-bribery laws prohibit UPS (or
any of its worldwide businesses, affiliates, employees, or representatives)
from bribing—or offering, promising, or authorizing anything of value
to—a foreign government official or employee in order to obtain or
retain business in an improper manner. We must be aware of these
strict prohibitions even when considering such hospitality as meals,
entertainment, gifts, or sponsorships involving a foreign government
official or employee. We conduct our business in accordance with the
FCPA and all applicable anti-bribery laws, and every one of us, regardless
of the country in which we work, must adhere to its requirements.
Under the FCPA as well as other anti-bribery laws, UPS, its employees,
and its representatives also are prohibited from doing indirectly what we
are prohibited from doing directly—we cannot make any payment to a
third party if all or any part of the payment will be given to a prohibited
person or organization. UPS could be held liable for such payments even if
the company did not know, but should have known, that the payment was
going to a prohibited person or organization. This liability could result
in severe consequences to the company, as well as all employees or third-
party representatives engaged in the misconduct.
In addition to the strict prohibitions relating to improper payments,
the FCPA and other anti-bribery laws also require that companies like
UPS maintain accurate books and records, which transparently capture
payments involving foreign government officials and employees. UPS has
established policies and procedures to ensure employees and third-party
representatives adhere to the FCPA and other anti-bribery laws. Key
components of the UPS Anti-Corruption Compliance Program include due
diligence, training, and monitoring of third-party representatives, as well
as appropriate accounting controls. Details are provided in the UPS Anti-
Corruption Compliance Manual.
All management employees are expected to become familiar with the Anti-
Corruption Compliance Manual, and how the responsibilities contained
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