Elon Musk is well known for his brevity on Twitter, and Tesla’s worldwide bribery and anti-corruption policy shows the compliance department also likes to keep things simple.
1. A whole policy in 10 words.
Boiled down to its essence, our policy is:
Don’t offer any bribe to anybody, anytime, for any reason.
(And when in doubt, please consult with the General Counsel or the Legal Department.)
2. Talking about the risk to the brand up front.
From the “Overview” section:
Involvement in bribery or corruption can result in lasting damage to our brand and our reputation. It can also result in multi-million-dollar fines and penalties, plus jail time for participants.
3. A $50 limit on gifts, meals, and entertainment.
In the normal course of business and depending upon the circumstances, a non-cash gift, meal or entertainment of USD $50 a person or less would be considered modest and reasonable.
4. Some facilitating payments might be approved.
Facilitation payments are not permissible, except in certain limited circumstances. You must obtain express written approval from the General Counsel or the Legal Department prior to making facilitating payments of any kind.
This policy is different from Apple, which doesn’t allow any facilitating payments.
5. No political contributions, even if legal.
Other than a political contribution specifically approved in writing by the General Counsel or the Legal Department, no political contribution shall be made, directly or indirectly, with corporate funds or assets regardless of whether the contributions are legal under the laws of the country in which they are made.
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Here’s the full five-page anti-corruption policy:tesla-worldwide-bribery-and-anti-corruption-policy_fcpa_blog