Anti-Bribery and Anti-Corruption
Many countries in which Amgen has operations have enacted anti-corruption legislation. For example, the U.S. Foreign Corrupt Practices Act (the “FCPA”) is a U.S. federal statute that, among other things, makes it illegal to make payments to government officials of any country outside of the U.S. for the purpose of obtaining or retaining business. Under Amgen’s policy, bribery and corruption is defined as the direct or indirect (i.e., through a third party), offer, promise, give, accept, or solicit of anything of value in order to obtain an improper advantage by influencing the judgment or conduct of a person. The FCPA also requires U.S. companies and their affiliates to keep accurate books and records and to maintain internal accounting controls to ensure that transactions are executed in accordance with management’s instructions and properly recorded on the company’s books. Anti-corruption legislation in other countries is similar to the FCPA but in some cases, the requirements of other countries’ laws go even further than the requirements of the FCPA. Individuals subject to this policy are required to comply with local requirements. For guidance on specific local laws, Amgen staff members at all Amgen sites must consult the Law Department.
Individuals subject to this policy must not offer, promise, give, accept or solicit – directly or indirectly – any payment (whether cash or non-cash) or any other advantage or thing of value to any Foreign Government Official or any other Third Party as an improper inducement for such person to take any action, or refrain from taking any action, that benefits Amgen businesses.
Amgen’s anti-bribery and anti-corruption effort is led by Senior Leadership and includes training our staff on bribery and corruption laws and principles that are aligned with our Anti-Bribery and Anti-Corruption policy via our annual Code of Conduct training. In addition, risk assessments are periodically performed in the bribery and corruption space to support programmatic opportunities as well as on-going audit and monitoring activities.