Always work honestly and with integrity. Never offer or accept a bribe from anyone, including — and remember, we are not only responsible for our actions, but also for the actions of any third party who represents Danaher including distributors, sales agents, representatives, consultants and logistics providers.
The laws in some countries impose additional penalties for bribing government officials, but for us it is simple: offering or accepting a bribe from anyone, at any time is always wrong.
- Do not give or accept , kickbacks, or accept or provide any other kind of improper payment.
- Do not pay . If a facilitation payment is requested, report the request to the Legal Department.
- Keep accurate books and records so that payments can be honestly described and documented.
- Be aware of our anti-corruption and bribery standards when selecting third parties that provide services on our behalf. Be vigilant and monitor their behavior.
- Be aware that not reporting a bribe or other illegal activity may itself be a violation of our Code.
I was authorized to hire a consultant to help us get the local permits needed for a new project. They asked for a $40,000 retainer to "help move the process along". Should I agree to this payment?
No. Before engaging the consultant, you need to consult with the Legal Department or use Speak Up! Before agreeing to make any payment, we need to know how the money will be used. Danaher must make sure this money is not used as a bribe, or any other improper payment.
I work in a country that is generally considered high-risk for bribery and corruption. My team needs approval from a state-owned company before we can contract with a preferred supplier of a major item of equipment. We are considering paying for several employees of the state-owned company and their spouses to travel to the U.S. for a week, to attend a day of meetings followed by shopping and sightseeing. These employees are not considered to be government officials under local law, so do I need to get advance approval?
Yes, and you need to review the situation with the Legal Department. The definitions of a government official in the US under the Foreign Corrupt Practices Act (FCPA), and under the UK anti-bribery laws, as well as similar laws of other countries, may be broader than local law, and therefore could include employees of the state-owned company. If this is the case, the proposed hosting of travel for the employees and their spouses would not be approved.