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Last updated: January 2025

Overview

Validcare, LLC maintains strict ethical standards in all business operations. We prohibit bribery and improper payments globally, covering all officers, employees, and agents acting on our behalf.

Regulatory Framework

This policy addresses compliance with:

  • U.S. Foreign Corrupt Practices Act (FCPA)
  • UK Bribery Act (UKBA)
  • Similar international anti-corruption regulations

A bribe or other improper payment to secure a business advantage is never acceptable and can result in criminal prosecution.

Prohibited Conduct

The following activities are strictly forbidden:

  • Cash bribes and kickbacks
  • Excessive gifts or entertainment
  • Employment offers to officials' family members as inducements
  • Political contributions used as inducements
  • Charitable donations used to gain improper business advantages
  • Investment opportunities or favorable contracts offered improperly

Definition of Foreign Officials

Our policy defines foreign officials broadly to include:

  • Government employees at all levels (local, regional, national)
  • Officials of state-owned enterprises
  • Private citizens exercising governmental authority
  • Officers and employees of public international organizations
  • Political party officials and candidates

Accountability Requirements

All personnel must:

  • Maintain accurate books and records
  • Conduct due diligence on third-party agents
  • Monitor business relationships for "red flags"
  • Report suspected violations promptly to supervisors or the Compliance Officer

Enforcement

Violations of this policy result in disciplinary action up to and including termination and potential criminal prosecution. Validcare prohibits retaliation against good-faith reporters of suspected violations.

Contact Information

To report concerns or ask questions about this policy: