WELL’s Foreign Corrupt Practices Act Program
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