It
is WELL's strict policy to conduct all its business legally
and with integrity and transparency.
WELL is committed
to compliance with the FCPA and other anti-bribery laws
where we operate.
Focus of the
FCPA Program
- WELL's Policy: Zero
Tolerance of bribery
-
Accounting: Accuracy,
transparency and internal controls
-
Discipline & Enforcement:
Up to and including termination
-
Agents, Consultants, Representatives & Intermediaries Who Interact with Public Officials
on WELL's Behalf: Internal due diligence to ensure
reputation for integrity and competence before
engagement contractual reps/warranties, written anti-bribery certifications,
training & monitoring
-
Facilitating Payments: Prohibited without written authorization from client and
company, except to protect personal health or safety
-
Gifts, Travel, Entertainment
of Public Officials: Internal, authorized limits
-
Charitable Contributions: Due diligence, Internal authorization required
-
Political Contributions: Strictly prohibited
-
Mergers, Acquisitions, JV's: Due diligence, contractual measures to ensure relationships
with reputable and competent business partners
- Reporting and Investigations: Company Compliance Officers
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