8.2.2 Foreign Corrupt Practices Act (FCPA) Policy

It is the policy of Georgia Tech that each of our employees, faculty, staff, agents, representatives, vendors and other third parties that work with GIT, GTRC and GTARC comply with the anti-bribery laws of the United States and of the foreign countries where Georgia Tech does business. Bribery of any kind in the United States and abroad, regardless of foreign custom or practice, is strictly prohibited. No Georgia Tech employee, faculty, staff, agent, representative, vendor or any other third party with which Georgia Tech works shall make any payment or provide anything of value, to any person, in order to improperly influence that person to secure any advantage for Georgia Tech, including obtaining or retaining business, or directing business to any person or entity. It is also the policy of Georgia Tech that each of its employees, faculty, staff, agents, representatives, vendors and all third parties that work with Georgia Tech make and keep books, records, and accounts, which, in reasonable detail, accurately reflect any transactions and dispositions of the university and any of its subsidiaries or partners. Any contracts involving, directly or indirectly, foreign officials must be in writing and reviewed by the Georgia Tech Office of Legal Affairs prior to execution. The Foreign Corrupt Practices Act (FCPA) is a federal law (15 U.S.C. § 78-dd-21 et seq.) that exists to prevent corrupt practices in international transactions. The Act prohibits bribery of foreign officials and employees who work for foreign governments. The FCPA prohibits the corrupt payment (or offer, promise or authorization of payment) of anything of value to any foreign official or employee, directly or indirectly, for the purpose of obtaining or retaining business, directing business to any person or entity, or securing any improper advantage. The FCPA’s prohibitions are applicable to United States organizations, public or private, and any person, including a foreign person or firm, if they commit a prohibited act in the United States. Further, a United States entity may be held liable under the FCPA for the improper activities of its foreign subsidiaries if the United States entity authorized or participated in the conduct. This policy ensures the Georgia Tech community is aware of, monitors, and complies with this statute.