FCPA Compliance

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