The U.S. Foreign Corrupt Practices Act (FCPA), as well as U.S. and foreign anti-corruption laws, prohibits organizations like the WMF from making “corrupt payments” or bribes to U.S. and foreign officials. See Wikipedia:Foreign Corrupt Practices Act. WMF employees, our contractors, and those acting on our behalf, including office volunteers, must comply with the FCPA and these anti-corruption laws.
We believe that the FCPA and anti-corruptions laws are consistent with both our Code of Conduct (Foundation:Code of Conduct Policy) and our values regarding community transparency (Foundation:Values). With this policy, we seek to promote these ideals and maintain the highest degree of integrity as an organization.
Whom Does This Policy Apply To?
This policy applies to WMF, persons working or volunteering for WMF, our contractors, and those acting on behalf of the WMF anywhere in the world.
What Does This Policy Prohibit?
WMF prohibits the exchange of cash or gifts for any official favor. Specifically, this precludes giving anything of value to any government official (or to a member of a public international organization, a political party, a political candidate, or their agent) for the purposes of improperly influencing official conduct in any manner.
Employees and others should be particularly alert where officials attempt to solicit bribes in subtle or nondescript ways. Here are some examples:
- A judge or court official offers to favor one side “in return for a personal favor”;
- A state university professor conditions a Campus Ambassador's access to his class upon the payment of an “additional fee” to him; or
- A government official insists on a “tip” before processing paperwork for an office we intend to establish in the country.
If you have any questions or concerns, please contact the Office of the General Counsel for more information and guidance.