Anti-Bribery Training Cerner has zero tolerance
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Anti-Bribery Training Cerner has zero tolerance for bribery or corrupt business practices. Under no circumstances should any Cerner Associate ever offer, directly or indirectly, any form of gift, entertainment or anything of value to any
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Anti-Bribery Training<br>
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Cerner has zero tolerance for bribery or corrupt business practices. Under no circumstances should any Cerner Associate ever offer, directly or indirectly, any form of gift, entertainment or anything of value to any client or prospective client in order to obtain or retain business, influence business decisions, or secure an unfair advantage. We expect all associates to use their best efforts to foster an environment of compliance and to encourage their fellow associates to act in Cerner’s best interest and in accordance with applicable laws, rules and regulations. Zane Burke President<br>
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BRNDEXP 3.0 © Cerner Corporation. All rights reserved.
This document contains Cerner confidential and/or proprietary information belonging to Cerner Corporation and/or its related affiliates which may not be reproduced or transmitted in any form or by any means without the express written consent of Cerner. 2 Training Overview Welcome to Cerner’s Anti-Bribery Training. By the end of this course, you will be able to:
Understand what constitutes bribery and common types of bribery.
Understand situations in which well-known companies faced bribery prosecution and the risk to Cerner.
Apply your knowledge to “real-life” examples.
Understand your obligations as a Cerner associate, how to report concerns or suspicions, and where to seek advice.
The following slides provide the content to prepare you for a short quiz at the end of the training.<br>
This document contains Cerner confidential and/or proprietary information belonging to Cerner Corporation and/or its related affiliates which may not be reproduced or transmitted in any form or by any means without the express written consent of Cerner. 2 Training Overview Welcome to Cerner’s Anti-Bribery Training. By the end of this course, you will be able to:
Understand what constitutes bribery and common types of bribery.
Understand situations in which well-known companies faced bribery prosecution and the risk to Cerner.
Apply your knowledge to “real-life” examples.
Understand your obligations as a Cerner associate, how to report concerns or suspicions, and where to seek advice.
The following slides provide the content to prepare you for a short quiz at the end of the training.<br>
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BRNDEXP 3.0 © Cerner Corporation. All rights reserved.
This document contains Cerner confidential and/or proprietary information belonging to Cerner Corporation and/or its related affiliates which may not be reproduced or transmitted in any form or by any means without the express written consent of Cerner. 3 What is Bribery? Bribery is the offer or promise to pay money or anything of value in order to influence an act or decision with the intent to obtain or retain business.
A bribe is not only a briefcase full of cash secretly exchanged in a back alley or funds wired to an off-shore account. A bribe can be anything of value to the person being bribed . . . e.g. a nice watch, a vacation disguised as a business trip.
Activities commonly influenced with bribery:
Winning a contract
The procurement process
Gaining access to non-public bid tender information
Avoiding contract termination<br>
This document contains Cerner confidential and/or proprietary information belonging to Cerner Corporation and/or its related affiliates which may not be reproduced or transmitted in any form or by any means without the express written consent of Cerner. 3 What is Bribery? Bribery is the offer or promise to pay money or anything of value in order to influence an act or decision with the intent to obtain or retain business.
A bribe is not only a briefcase full of cash secretly exchanged in a back alley or funds wired to an off-shore account. A bribe can be anything of value to the person being bribed . . . e.g. a nice watch, a vacation disguised as a business trip.
Activities commonly influenced with bribery:
Winning a contract
The procurement process
Gaining access to non-public bid tender information
Avoiding contract termination<br>
05
BRNDEXP 3.0 © Cerner Corporation. All rights reserved.
This document contains Cerner confidential and/or proprietary information belonging to Cerner Corporation and/or its related affiliates which may not be reproduced or transmitted in any form or by any means without the express written consent of Cerner. 4 Anti-Bribery Laws As a global company, Cerner and all associates (regardless of office location) are required to comply with multiple anti-bribery laws and conventions
You and Cerner are liable under domestic laws for any corrupt acts committed abroad.
You and Cerner are liable under national laws in the countries in which you do business.
You and Cerner could be liable under the US Foreign Corrupt Practices Act (FCPA) and UK Bribery Act because they have extra-territorial reach.
Key Anti-Bribery Legislation
While each of these laws is different in scope and reach, the corrupt activities they prohibit are the same and the focus of enforcement is generally the same – prosecute corruption in all its forms.<br>
This document contains Cerner confidential and/or proprietary information belonging to Cerner Corporation and/or its related affiliates which may not be reproduced or transmitted in any form or by any means without the express written consent of Cerner. 4 Anti-Bribery Laws As a global company, Cerner and all associates (regardless of office location) are required to comply with multiple anti-bribery laws and conventions
You and Cerner are liable under domestic laws for any corrupt acts committed abroad.
You and Cerner are liable under national laws in the countries in which you do business.
You and Cerner could be liable under the US Foreign Corrupt Practices Act (FCPA) and UK Bribery Act because they have extra-territorial reach.
Key Anti-Bribery Legislation
While each of these laws is different in scope and reach, the corrupt activities they prohibit are the same and the focus of enforcement is generally the same – prosecute corruption in all its forms.<br>
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Enforcement BRNDEXP 3.0 © Cerner Corporation. All rights reserved.
This document contains Cerner confidential and/or proprietary information belonging to Cerner Corporation and/or its related affiliates which may not be reproduced or transmitted in any form or by any means without the express written consent of Cerner. 5 While the US leads the world in total numbers of investigations and enforcement actions, non-US authorities are beginning to take action against companies and individuals who have bribed foreign officials.
Enforcement of the FCPA remained a high priority for the US Department of Justice and the US Securities and Exchange Commission in 2016, resulting in record-setting enforcement numbers.
The US government added four new entries on its all-time top-ten FCPA enforcement list and received approximately $1.8 billion in monetary settlements, besting the prior record of $1.6 billion set in 2014.
The average cost to resolve an FCPA corporate action in 2014 was $114 million.<br>
This document contains Cerner confidential and/or proprietary information belonging to Cerner Corporation and/or its related affiliates which may not be reproduced or transmitted in any form or by any means without the express written consent of Cerner. 5 While the US leads the world in total numbers of investigations and enforcement actions, non-US authorities are beginning to take action against companies and individuals who have bribed foreign officials.
Enforcement of the FCPA remained a high priority for the US Department of Justice and the US Securities and Exchange Commission in 2016, resulting in record-setting enforcement numbers.
The US government added four new entries on its all-time top-ten FCPA enforcement list and received approximately $1.8 billion in monetary settlements, besting the prior record of $1.6 billion set in 2014.
The average cost to resolve an FCPA corporate action in 2014 was $114 million.<br>
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Common Forms of Bribery Agents or Contractors BRNDEXP 3.0 © Cerner Corporation. All rights reserved.
This document contains Cerner confidential and/or proprietary information belonging to Cerner Corporation and/or its related affiliates which may not be reproduced or transmitted in any form or by any means without the express written consent of Cerner. 6 Bribery via agents, consultants, or contractors is common. A company can be prosecuted for a bribe offered by a contractor, even if the company had no knowledge of the bribe.
Example: HP's subsidiary in Mexico paid a consultant to help the company win a public IT contract worth approximately $6 million. At least $125,000 was funneled to a government official at the state-owned petroleum company with whom the consultant had connections. “You’ll get the deal.
I have connections.” Takeaways:
Thoroughly research the third party’s background prior to recommending that they be hired.
Cerner should enter into a written contract with the third party that defines the specific duties of the third party. Follow the standard Supplier Contracting process via Finance and Legal.
If the fees negotiated by the third party are higher than market rates, alert Cerner Legal.
The associate assigned to manage the third party relationship should be cognizant of close relationships with government officials (familial or otherwise), requests that payments be sent to a different account, and duties performed which were not outlined in the contract.<br>
This document contains Cerner confidential and/or proprietary information belonging to Cerner Corporation and/or its related affiliates which may not be reproduced or transmitted in any form or by any means without the express written consent of Cerner. 6 Bribery via agents, consultants, or contractors is common. A company can be prosecuted for a bribe offered by a contractor, even if the company had no knowledge of the bribe.
Example: HP's subsidiary in Mexico paid a consultant to help the company win a public IT contract worth approximately $6 million. At least $125,000 was funneled to a government official at the state-owned petroleum company with whom the consultant had connections. “You’ll get the deal.
I have connections.” Takeaways:
Thoroughly research the third party’s background prior to recommending that they be hired.
Cerner should enter into a written contract with the third party that defines the specific duties of the third party. Follow the standard Supplier Contracting process via Finance and Legal.
If the fees negotiated by the third party are higher than market rates, alert Cerner Legal.
The associate assigned to manage the third party relationship should be cognizant of close relationships with government officials (familial or otherwise), requests that payments be sent to a different account, and duties performed which were not outlined in the contract.<br>
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BRNDEXP 3.0 © Cerner Corporation. All rights reserved.
This document contains Cerner confidential and/or proprietary information belonging to Cerner Corporation and/or its related affiliates which may not be reproduced or transmitted in any form or by any means without the express written consent of Cerner. 7 Common Forms of Bribery Charitable Contributions Even a charitable contribution can be deemed a bribe, if funds were diverted to decision makers or if the contribution itself influenced their decision.
Example*: A pharma company used charitable donations to a small local castle restoration charity headed by a foreign government official to induce the official to direct business to the company. Even though the charity was a legitimate charitable organization, internal documents at the pharma company established that the payments were viewed as “dues” it was required to pay for assistance from the government official. The payments also were not in compliance with the company’s internal policies.
*excerpt from DOJ/SEC Resource Guide Takeaway: Follow Cerner’s Global Code of Conduct and Charitable Contribution Policy anytime someone requests a donation. A form with questions designed to protect against a potential bribery situation should be completed.<br>
This document contains Cerner confidential and/or proprietary information belonging to Cerner Corporation and/or its related affiliates which may not be reproduced or transmitted in any form or by any means without the express written consent of Cerner. 7 Common Forms of Bribery Charitable Contributions Even a charitable contribution can be deemed a bribe, if funds were diverted to decision makers or if the contribution itself influenced their decision.
Example*: A pharma company used charitable donations to a small local castle restoration charity headed by a foreign government official to induce the official to direct business to the company. Even though the charity was a legitimate charitable organization, internal documents at the pharma company established that the payments were viewed as “dues” it was required to pay for assistance from the government official. The payments also were not in compliance with the company’s internal policies.
*excerpt from DOJ/SEC Resource Guide Takeaway: Follow Cerner’s Global Code of Conduct and Charitable Contribution Policy anytime someone requests a donation. A form with questions designed to protect against a potential bribery situation should be completed.<br>
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BRNDEXP 3.0 © Cerner Corporation. All rights reserved.
This document contains Cerner confidential and/or proprietary information belonging to Cerner Corporation and/or its related affiliates which may not be reproduced or transmitted in any form or by any means without the express written consent of Cerner. 8 Common Forms of Bribery Gifts and Entertainment A small gift or token of gratitude which is unlikely to improperly influence a decision maker may be appropriate; however, the larger or more extravagant the gift, the more likely it was given with an improper purpose.
Examples*:
A $12,000 birthday trip (charged to expense as “training”) to the U.S. for a government decision-maker from Mexico that included visits to wineries and dinners.
$10,000 spent on dinners, drinks, and entertainment for a decision maker.
A trip to Italy for eight Iraqi officials disguised as a reference visit that consisted primarily of sightseeing and included $1,000 in “pocket money” for each official.
*excerpt from DOJ/SEC Resource Guide Takeaways:
Seek pre-clearance from Legal prior to agreeing that Cerner fund, subsidize, or reimburse any client travel (e.g. CHC packages, Vision Center visits, training, etc.). Legitimate expenditures made in connection with the promotion, demonstration, or explanation of products or services are allowed. See Checklist – Cerner Funded Trips in the Appendix.
Choose reasonably-priced restaurants or modest entertainment. Err on the side of caution to avoid any misinterpretation.
Any gifts given where customary and appropriate under local law, should be made openly, transparently and charged to the correct category in the expense report.<br>
This document contains Cerner confidential and/or proprietary information belonging to Cerner Corporation and/or its related affiliates which may not be reproduced or transmitted in any form or by any means without the express written consent of Cerner. 8 Common Forms of Bribery Gifts and Entertainment A small gift or token of gratitude which is unlikely to improperly influence a decision maker may be appropriate; however, the larger or more extravagant the gift, the more likely it was given with an improper purpose.
Examples*:
A $12,000 birthday trip (charged to expense as “training”) to the U.S. for a government decision-maker from Mexico that included visits to wineries and dinners.
$10,000 spent on dinners, drinks, and entertainment for a decision maker.
A trip to Italy for eight Iraqi officials disguised as a reference visit that consisted primarily of sightseeing and included $1,000 in “pocket money” for each official.
*excerpt from DOJ/SEC Resource Guide Takeaways:
Seek pre-clearance from Legal prior to agreeing that Cerner fund, subsidize, or reimburse any client travel (e.g. CHC packages, Vision Center visits, training, etc.). Legitimate expenditures made in connection with the promotion, demonstration, or explanation of products or services are allowed. See Checklist – Cerner Funded Trips in the Appendix.
Choose reasonably-priced restaurants or modest entertainment. Err on the side of caution to avoid any misinterpretation.
Any gifts given where customary and appropriate under local law, should be made openly, transparently and charged to the correct category in the expense report.<br>
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BRNDEXP 3.0 © Cerner Corporation. All rights reserved.
This document contains Cerner confidential and/or proprietary information belonging to Cerner Corporation and/or its related affiliates which may not be reproduced or transmitted in any form or by any means without the express written consent of Cerner. 9 Corruption Perception Index Scores The Corruption Perception Index* measures the perceived levels of corruption in 180 countries worldwide.
Countries are scored from 0 (highly corrupt) to 100 (highly transparent).
Scores for a sample of the countries in which Cerner operates: *Transparency International, a highly respected, not-for-profit, multi-national organization whose mission is to promote integrity, transparency, and accountability at all levels and across all sectors of society, publishes the Corruption Perception Index annually to measure the level of corruption in each country. http://www.transparency.org/<br>
This document contains Cerner confidential and/or proprietary information belonging to Cerner Corporation and/or its related affiliates which may not be reproduced or transmitted in any form or by any means without the express written consent of Cerner. 9 Corruption Perception Index Scores The Corruption Perception Index* measures the perceived levels of corruption in 180 countries worldwide.
Countries are scored from 0 (highly corrupt) to 100 (highly transparent).
Scores for a sample of the countries in which Cerner operates: *Transparency International, a highly respected, not-for-profit, multi-national organization whose mission is to promote integrity, transparency, and accountability at all levels and across all sectors of society, publishes the Corruption Perception Index annually to measure the level of corruption in each country. http://www.transparency.org/<br>
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Countries with Increased Bribery Risk BRNDEXP 3.0 © Cerner Corporation. All rights reserved.
This document contains Cerner confidential and/or proprietary information belonging to Cerner Corporation and/or its related affiliates which may not be reproduced or transmitted in any form or by any means without the express written consent of Cerner. 10 Corruption exists all over the world, but unfortunately it is accepted as a way of doing business in some countries.
Cerner prohibits all types of bribery, regardless of local culture, customs, or situation.
Cerner associates who commit bribes are subject to internal corrective action and can face civil and criminal penalties.<br>
This document contains Cerner confidential and/or proprietary information belonging to Cerner Corporation and/or its related affiliates which may not be reproduced or transmitted in any form or by any means without the express written consent of Cerner. 10 Corruption exists all over the world, but unfortunately it is accepted as a way of doing business in some countries.
Cerner prohibits all types of bribery, regardless of local culture, customs, or situation.
Cerner associates who commit bribes are subject to internal corrective action and can face civil and criminal penalties.<br>
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Hypothetical #1 BRNDEXP 3.0 © Cerner Corporation. All rights reserved.
This document contains Cerner confidential and/or proprietary information belonging to Cerner Corporation and/or its related affiliates which may not be reproduced or transmitted in any form or by any means without the express written consent of Cerner. 11 For the past several weeks you have been working on a bid for the government of Cernerville, and the proposal was presented this afternoon. At the end of the meeting, the potential client has some questions on the specifics of the bid and would like to continue the discussion over dinner. Is it okay for Cerner to pay for dinner?
Many government entities place restrictions on the acceptance of gifts by their officials. In addition to anti-bribery laws, we must comply with the policies of the officials’ employer as well as any local regulations.
If allowable by employer and local regulations, generally this situation would be compliant if the dinner has a business-related purpose and is not excessive in amount.<br>
This document contains Cerner confidential and/or proprietary information belonging to Cerner Corporation and/or its related affiliates which may not be reproduced or transmitted in any form or by any means without the express written consent of Cerner. 11 For the past several weeks you have been working on a bid for the government of Cernerville, and the proposal was presented this afternoon. At the end of the meeting, the potential client has some questions on the specifics of the bid and would like to continue the discussion over dinner. Is it okay for Cerner to pay for dinner?
Many government entities place restrictions on the acceptance of gifts by their officials. In addition to anti-bribery laws, we must comply with the policies of the officials’ employer as well as any local regulations.
If allowable by employer and local regulations, generally this situation would be compliant if the dinner has a business-related purpose and is not excessive in amount.<br>
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Hypothetical #2 BRNDEXP 3.0 © Cerner Corporation. All rights reserved.
This document contains Cerner confidential and/or proprietary information belonging to Cerner Corporation and/or its related affiliates which may not be reproduced or transmitted in any form or by any means without the express written consent of Cerner. 12 Cerner is working to develop business in a new country. Since Cerner is new to the market, a potential client expects Cerner to pay for a trip to Kansas City so that the team can visit the Vision Center and further understand Cerner’s solutions and offerings. Can Cerner pay for this travel? Can Cerner pay for a sightseeing trip while the potential client is visiting?
It is normally permissible for a company to pay for the travel expenses of clients or potential clients to travel to tour facilities, view solution demonstrations, or attend training.
It is not acceptable for Cerner to fund any non-business portions of the trip or to pay for expenses related to a spouse or other individual not employed by the client/potential client.
Prior to paying or agreeing to pay or reimburse for travel-related expenses, associates must: i) confirm with Cerner Legal that Cerner’s payment of such travel-related expenses is permissible, and ii) confirm with the client/potential client that such activity is permissible under the client/potential client’s internal policies and procedures.
Additionally, expenses must be reasonable, business related, and properly recorded. Payment should be reimbursed directly to the supplier, not the client/potential client, unless receipts are submitted. The client/potential client’s representatives should be chosen by the client/potential client, not by Cerner.
See Checklist for Cerner Funded Trips in the Appendix.<br>
This document contains Cerner confidential and/or proprietary information belonging to Cerner Corporation and/or its related affiliates which may not be reproduced or transmitted in any form or by any means without the express written consent of Cerner. 12 Cerner is working to develop business in a new country. Since Cerner is new to the market, a potential client expects Cerner to pay for a trip to Kansas City so that the team can visit the Vision Center and further understand Cerner’s solutions and offerings. Can Cerner pay for this travel? Can Cerner pay for a sightseeing trip while the potential client is visiting?
It is normally permissible for a company to pay for the travel expenses of clients or potential clients to travel to tour facilities, view solution demonstrations, or attend training.
It is not acceptable for Cerner to fund any non-business portions of the trip or to pay for expenses related to a spouse or other individual not employed by the client/potential client.
Prior to paying or agreeing to pay or reimburse for travel-related expenses, associates must: i) confirm with Cerner Legal that Cerner’s payment of such travel-related expenses is permissible, and ii) confirm with the client/potential client that such activity is permissible under the client/potential client’s internal policies and procedures.
Additionally, expenses must be reasonable, business related, and properly recorded. Payment should be reimbursed directly to the supplier, not the client/potential client, unless receipts are submitted. The client/potential client’s representatives should be chosen by the client/potential client, not by Cerner.
See Checklist for Cerner Funded Trips in the Appendix.<br>
14
BRNDEXP 3.0 © Cerner Corporation. All rights reserved.
This document contains Cerner confidential and/or proprietary information belonging to Cerner Corporation and/or its related affiliates which may not be reproduced or transmitted in any form or by any means without the express written consent of Cerner. 13 You are a newly promoted executive. After three weeks, you locate a partner to assist with getting our foot in the door with local hospitals. The potential partner, Healthcare Connections, has guaranteed meetings over the next three months with top individuals in the hospital system. Healthcare Connections has proposed a partnership agreement that would require Cerner to compensate them at 5% of all Millennium deals closed as a result of their services. Healthcare Connections has asked you to sign the contract by Friday, or they plan to align with Epic. What should you do?
Agreements based on percentage of contracted business are typically not appropriate because they cannot be linked directly to specific services rendered.
All Cerner contracts must be reviewed, approved and executed by an authorized signatory as specifically set forth in the Contracting & Signatory Authority Policy.
All third parties should be thoroughly researched. How does the local partner maintain its relationships so that individuals would be willing to meet with Cerner? Is any sort of inducement offered by the local partner?
Contact Cerner Legal before proceeding. Hypothetical #3<br>
This document contains Cerner confidential and/or proprietary information belonging to Cerner Corporation and/or its related affiliates which may not be reproduced or transmitted in any form or by any means without the express written consent of Cerner. 13 You are a newly promoted executive. After three weeks, you locate a partner to assist with getting our foot in the door with local hospitals. The potential partner, Healthcare Connections, has guaranteed meetings over the next three months with top individuals in the hospital system. Healthcare Connections has proposed a partnership agreement that would require Cerner to compensate them at 5% of all Millennium deals closed as a result of their services. Healthcare Connections has asked you to sign the contract by Friday, or they plan to align with Epic. What should you do?
Agreements based on percentage of contracted business are typically not appropriate because they cannot be linked directly to specific services rendered.
All Cerner contracts must be reviewed, approved and executed by an authorized signatory as specifically set forth in the Contracting & Signatory Authority Policy.
All third parties should be thoroughly researched. How does the local partner maintain its relationships so that individuals would be willing to meet with Cerner? Is any sort of inducement offered by the local partner?
Contact Cerner Legal before proceeding. Hypothetical #3<br>
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Anti-Bribery Resources BRNDEXP 3.0 © Cerner Corporation. All rights reserved.
This document contains Cerner confidential and/or proprietary information belonging to Cerner Corporation and/or its related affiliates which may not be reproduced or transmitted in any form or by any means without the express written consent of Cerner. 14 Cerner Legal Contacts
US: Amy Abrams, Sr. Corporate Counsel – 816.201.0635 or Marc Elkins, Chief Compliance Officer – 816.201.0550 (Dial country code if calling from outside the U.S.)
Australia, Malaysia, and Singapore: Michelle Fisher, Sr. Corporate Counsel - +61 2 9900 4846
India, UAE and Cerner Middle East: Anis Zerriny, Corporate Counsel - +971 4 3754870
UK and Europe: Jana Fuchs, Corporate Counsel - +4940303335931
Cerner’s Ethics Hotline
Cerner’s Ethics Hotline is available 24 hours a day, 7 days a week by dialing 1.800.338.9086 (Dial country code if calling from outside the U.S.). Dial 91 80 3078 1021 if calling from India.
You may remain anonymous if you so choose, except where restricted by local law (e.g. France and Spain).
Due to local privacy laws in certain countries and the European Union, the Ethics Hotline may permit only specific types of calls, such as financial, accounting, auditing and bribery related offenses. In those countries, contact your HR Partner to report other issues.
Cerner Policies
Global Code of Conduct
Cerner’s Anti-Bribery Policy and Standard Operating Procedures
Purchasing Policy
Charitable Contributions Policy
References
FCPA overview and SEC/DOJ Resource Guide
UK Bribery Act and Ministry of Justice Resource Guide
Brazil Clean Companies Act
German Anti-Corruption Law<br>
This document contains Cerner confidential and/or proprietary information belonging to Cerner Corporation and/or its related affiliates which may not be reproduced or transmitted in any form or by any means without the express written consent of Cerner. 14 Cerner Legal Contacts
US: Amy Abrams, Sr. Corporate Counsel – 816.201.0635 or Marc Elkins, Chief Compliance Officer – 816.201.0550 (Dial country code if calling from outside the U.S.)
Australia, Malaysia, and Singapore: Michelle Fisher, Sr. Corporate Counsel - +61 2 9900 4846
India, UAE and Cerner Middle East: Anis Zerriny, Corporate Counsel - +971 4 3754870
UK and Europe: Jana Fuchs, Corporate Counsel - +4940303335931
Cerner’s Ethics Hotline
Cerner’s Ethics Hotline is available 24 hours a day, 7 days a week by dialing 1.800.338.9086 (Dial country code if calling from outside the U.S.). Dial 91 80 3078 1021 if calling from India.
You may remain anonymous if you so choose, except where restricted by local law (e.g. France and Spain).
Due to local privacy laws in certain countries and the European Union, the Ethics Hotline may permit only specific types of calls, such as financial, accounting, auditing and bribery related offenses. In those countries, contact your HR Partner to report other issues.
Cerner Policies
Global Code of Conduct
Cerner’s Anti-Bribery Policy and Standard Operating Procedures
Purchasing Policy
Charitable Contributions Policy
References
FCPA overview and SEC/DOJ Resource Guide
UK Bribery Act and Ministry of Justice Resource Guide
Brazil Clean Companies Act
German Anti-Corruption Law<br>
16
Appendix Checklist for Cerner-Funded Trips BRNDEXP 3.0 © Cerner Corporation. All rights reserved.
This document contains Cerner confidential and/or proprietary information belonging to Cerner Corporation and/or its related affiliates which may not be reproduced or transmitted in any form or by any means without the express written consent of Cerner. 15 Prior to seeking clearance from Legal for Cerner to fund, reimburse, or subsidize client or prospective client travel, please consider the following guidance from the DOJ/SEC Resource Guide:
Do not select the particular officials who will participate in the party’s proposed trip or program.
Pay all costs directly to travel and lodging suppliers and/or reimburse costs only upon presentation of a receipt.
Do not advance funds or pay for reimbursements in cash.
Ensure that any stipends are reasonable approximations of costs likely to be incurred and/or that expenses are limited to those that are necessary and reasonable.
Ensure the expenditures are transparent, both within the company and to the foreign government.
Do not condition payment of expenses on any action by the foreign official.
Obtain written confirmation that payment of the expenses is not contrary to local law.
Provide no additional compensation, stipends, or spending money beyond what is necessary to pay for actual expenses incurred.
Ensure that costs and expenses on behalf of the foreign officials will be accurately recorded in the companies' books and records.
The US Department of Justice opined that the following types of expenditures are acceptable:
Travel and expenses to visit company facilities or operations.
Travel and expenses for training.
Product demonstrations or promotional activities, including travel and expenses for meetings.<br>
This document contains Cerner confidential and/or proprietary information belonging to Cerner Corporation and/or its related affiliates which may not be reproduced or transmitted in any form or by any means without the express written consent of Cerner. 15 Prior to seeking clearance from Legal for Cerner to fund, reimburse, or subsidize client or prospective client travel, please consider the following guidance from the DOJ/SEC Resource Guide:
Do not select the particular officials who will participate in the party’s proposed trip or program.
Pay all costs directly to travel and lodging suppliers and/or reimburse costs only upon presentation of a receipt.
Do not advance funds or pay for reimbursements in cash.
Ensure that any stipends are reasonable approximations of costs likely to be incurred and/or that expenses are limited to those that are necessary and reasonable.
Ensure the expenditures are transparent, both within the company and to the foreign government.
Do not condition payment of expenses on any action by the foreign official.
Obtain written confirmation that payment of the expenses is not contrary to local law.
Provide no additional compensation, stipends, or spending money beyond what is necessary to pay for actual expenses incurred.
Ensure that costs and expenses on behalf of the foreign officials will be accurately recorded in the companies' books and records.
The US Department of Justice opined that the following types of expenditures are acceptable:
Travel and expenses to visit company facilities or operations.
Travel and expenses for training.
Product demonstrations or promotional activities, including travel and expenses for meetings.<br>