Corruption harms citizens and communities, so combating bribery Bribery is offering, giving, receiving, soliciting, or accepting anything of value to get or keep a business advantage. and money laundering Money laundering happens when criminals move funds made from illegal activities through a legal business (like ours). is critical. Let’s work together to vet all of our third parties carefully and lead our industry with integrity.
Avoid bribes and kickbacks.
At FIS, we never bribe – or accept bribes – and we avoid even the appearance of anything improper. We also steer clear of kickbacks, which are items of value given after a deal is finalized. To do your part, keep in mind that bribes and kickbacks are not limited to cash. Watch out for the exchange of anything of value, including:
- Business gifts
- Entertainment
- Meals
- Discounts
- Favors
- Jobs or internships
- Cash or cash equivalents (like gift cards or gift certificates)
- Charitable or political contributions
Interact carefully with government officials.
The rules for what we can give or offer to government officials, and even their relatives, are very strict. Before you offer anything of value, get approval from the FIS Ethics Office.
FIS prohibits facilitation payments or “grease payments” offered to a person in government or other individual to secure or speed up a routine, discretionary government process or decision, such as expediting a license or permit. However, a narrow exception for facilitating or expediting payments exists if it’s made to further a routine government action that involves non-discretionary acts, such as expediting a passport.
The term government official is broad and not only applies to elected officials, but also to employees of government agencies and government-controlled companies or entities, like public schools and others as described in our Anti-Bribery and Anti-Corruption (FABAC) Policy.
Know your clients.
To prevent money laundering, it’s important to ensure payments come from legitimate sources and are used for legitimate business purposes only. Be sure to:
- Understand how clients use our services and solutions.
- Know who’s behind every transaction and only do business with those who are reputable.
- Report any suspicious activity or questionable transaction.
Questionable transactions can include:
- Attempts to pay in cash
- Requests to ship to a country other than where the payment originated
- Attempts to avoid recordkeeping requirements
- Payments made by individuals or companies who are not parties to the transaction
- Any suspicious change in the pattern of a client’s transactions
Additional Resources Available:
Anti-Bribery and Anti-Corruption (FABAC) Policy
Global Anti-Money Laundering and Counter-Terrorism Financing Policy
Environmental, Social, and Governance (ESG) Policy
Sanctions Compliance Policy
The term government official is broad and not only applies to elected officials, but also to employees of government agencies and government-controlled companies or entities, like public schools and others as described in our Anti-Bribery and Anti-Corruption (FABAC) Policy.
Questionable transactions can include:
- Attempts to pay in cash
- Requests to ship to a country other than where the payment originated
- Attempts to avoid recordkeeping requirements
- Payments made by individuals or companies who are not parties to the transaction
- Any suspicious change in the pattern of a client’s transactions
Our Core Values In Action
Q: A seemingly unrelated third party recently began making payments on behalf of one of our long-time distributors. I do not want to accuse the distributor of wrongdoing, but I’m concerned about the payments. What should I do?
A: Contact the distributor for details. If the responses you receive do not make sense or are unsatisfactory, report it to your manager or the FIS Ethics Office.