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Harry Cassin
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Editor Emeritus

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Thomas Fox
Contributing Editor

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ByteDance’s anti-bribery policy for the TikTok generation

ByteDance is a Chinese technology company that has given the world many products and a few revolutionary ones, including TikTok. What does their anti-bribery policy look like?

1. No public stand-alone anti-bribery policy. 

The only resources we could find for ByteDance’s anti-bribery policy is within the company’s code of conduct. The anti-bribery part gets a couple of paragraphs. Here it is in full:

We seek to preserve our culture of integrity and ethical behavior, as well as comply with all applicable anti-corruption laws and regulations in the countries in which we operate. We prohibit bribery in all forms. You may not, whether directly or indirectly, offer, give, receive, or solicit, anything of value to improperly influence any decision or any other act or omission related to the Company’s business or to obtain an improper advantage.

We do not maintain business relationships based on offering, or providing, gifts or entertainment. We understand that local business customs or etiquette may require the giving of a gift or entertainment on certain occasions. Nonetheless, the following conditions must be met when giving such gifts or entertainment:

– The gift or entertainment given should not violate applicable laws or Company policies, must have legitimate business purposes, be appropriate, and conform to local business etiquette.
– The Company prohibits offering, making any payment, or giving any lavish gift or entertainment, that could be considered a bribe, kickback, commission or advantage.
– Obtain the requisite pre-approvals for giving gifts or entertainment and maintain proper records.

2. No “lavish” gifts. (See above)

3. Facilitation Payments… N/A

Walmart is the only other company that doesn’t mention facilitating payments. Glencore, Ferrari, Kraft Heinz, Burberry, Disney, Unilever, Carlsberg, Apple, Novartis, Microsoft, Volkswagen, Airbus, GM, 3M, and Pfizer that all ban facilitating payments. Coca-Cola, Tesla, and ExxonMobil might approve some facilitating payments.

4. The extortion defense is AWOL.

ByteDance doesn’t mention extraordinary circumstances employees might face like extortion, duress, or danger.

5. Short, but maybe not so sweet. 

Unilever has a single page document for its anti-bribery policy. However, Unilever manages to cover topics like facilitating payments, the extortion defense, meeting public officials, and extending the policy to third parties.

– – – – –

View the two-paragraph ByteDance anti-bribery policy.

View more anti-corruption policy benchmarks here.


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