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The policy sets purpose, scope, and organizational responsibilities across global operations and “Covered Persons.” It prohibits offering, giving, demanding, or authorizing bribes or kickbacks, and requires accurate books and internal accounting controls. It also explains key FCPA and UK Bribery Act concepts and directs reporting of bribery demands to the appropriate legal counsel.",{"@graph":63,"@context":118},[64,80,101],{"@type":65,"itemListElement":66},"BreadcrumbList",[67,71,74,77],{"item":68,"name":69,"@type":70,"position":9},"https://docshare.wps.com","Home","ListItem",{"item":72,"name":10,"@type":70,"position":73},"https://docshare.wps.com/template/",2,{"item":75,"name":51,"@type":70,"position":76},"https://docshare.wps.com/template/general/",3,{"item":78,"name":59,"@type":70,"position":79},"https://docshare.wps.com/template/anti-bribery-and-anti-money-laundering-compliance-policy-effective-date-june-9-2022/282696/",4,{"url":78,"name":59,"@type":81,"image":82,"author":87,"headline":59,"publisher":90,"fileFormat":93,"inLanguage":57,"description":61,"dateModified":94,"datePublished":95,"encodingFormat":93,"isAccessibleForFree":96,"interactionStatistic":97},"DigitalDocument",{"url":83,"@type":84,"width":85,"height":86},"https://docshare.wps.com/thumbnails/anti-bribery-and-anti-money-laundering-compliance-policy-effective-date-june-9-2022/282696.png","ImageObject",442,249,{"name":88,"@type":89},"Blaney","Person",{"url":68,"name":91,"@type":92},"DocShare","Organization","application/pdf","2026-09-23","2026-09-16",true,{"@type":98,"interactionType":99,"userInteractionCount":73},"InteractionCounter",{"@type":100},"ViewAction",{"@type":102,"mainEntity":103},"FAQPage",[104,110,114],{"name":105,"@type":106,"acceptedAnswer":107},"Who does this Anti-Bribery Compliance Policy apply to?","Question",{"text":108,"@type":109},"The policy applies to Thermo Fisher’s worldwide operations, including divisions and subsidiaries, and to directors, officers, and employees (including temporary employees and contractors), as well as relevant distributors and business partners. All such individuals and entities are treated as “Covered Persons.”","Answer",{"name":111,"@type":106,"acceptedAnswer":112},"What actions are prohibited under the policy?",{"text":113,"@type":109},"Covered Persons must not engage in activities inconsistent with anti-corruption laws, accept or solicit bribes or undue advantages, or use contracts and payment vehicles to channel money to public officials or close family members of officials. It also prohibits authorizing or condoning prohibited conduct.",{"name":115,"@type":106,"acceptedAnswer":116},"How does the policy address reporting of bribery demands?",{"text":117,"@type":109},"Any demand for a bribe or payment of a bribe must be immediately brought to the attention of the Group General Counsel / Thermo Fisher General Counsel, available by phone or email. The policy emphasizes that bribes and kickbacks will not be offered, given, accepted, or tolerated.","https://schema.org",{"og:url":78,"og:type":120,"og:title":59,"og:site_name":91,"og:description":61},"article",{"robots":122,"canonical":78},"index,follow",{"doc_id":124,"site_id":56},282696,1790204335,{"code":4,"msg":5,"data":127},{"doc_id":124,"user_id":128,"nickname":88,"user_avatar":129,"doc_module":9,"category_id":50,"category_name":51,"doc_title":59,"doc_description":61,"doc_content":130,"file_id":131,"file_url":132,"file_type":133,"file_size":134,"view_count":76,"is_deleted":4,"is_public":9,"is_downloadable":9,"audit_status":9,"page_count":20,"language":135,"language_code":57,"site_id":56,"html_lang":57,"table_of_contents":136,"faqs":137,"seo_title":138,"seo_description":61,"update_tm":139,"read_time":47},1236954677761,"https://us-avatar.wpscdn.com/davatar_994ba38a5ba835b3df7d355c54d3ed8d","EFFECTIVE DATE: June 9, 2022  \n\n| Title: Anti-Bribery and Anti-Money Laundering Compliance Policy | Supersedes: December 15, 2021 | Total Pages: 11 |\n| --- | --- | --- |\n| Issued by: Legal Department | Author: ABAC Compliance | Rev: 5 |\n\nA. ANTI-BRIBERY COMPLIANCE POLICY  \n1.0 INTRODUCTION. Compliance is a core value for Thermo Fisher. Thermo Fisher is committed to conducting its business ethically and in full compliance with the laws of the countries where we operate. Thermo Fisher must comply with the U.S. Foreign Corrupt Practices Act of 1977, as amended (“FCPA”), the UK Bribery Act 2010 (“UK Bribery Act”), and all applicable anti-corruption laws, both domestically and internationally. Countries around the world are adopting anti-corruption laws, which make it a crime to make bribes. This policy sets the expectation and requirements for compliance with those laws.  \n2.0 PURPOSE. This Anti-Bribery Compliance Policy (“Policy”) provides a framework for (1) promoting effective compliance with applicable anti-corruption laws and regulations by relevant Thermo Fisher business organizations and other 3rd party intermediaries; (2) designating organizational responsibilities for compliance with these laws and regulations throughout Thermo Fisher’s business operations; and (3) encouraging a commitment to compliance with laws, transparency, and integrity in all business activities as set forth in Thermo Fisher’s Code of Business Conduct & Ethics. This Policy is supplemented by the Thermo Fisher Third Party Due Diligence-Standard Operating Procedure, which is described further in Exhibit C.  \n3.0 SCOPE. This Policy applies to all (i) operations of Thermo Fisher, including all of its divisions, subsidiaries, and affiliated companies worldwide and to Thermo Fisher's various distributors, sales agents, consultants, suppliers and other business partners; and (ii) directors, officers, and employees (including temporary employees and contractors) of Thermo Fisher, who are always defined herein as and considered to be “Covered Persons,” on a world-wide basis.  \n4.0 COMMITMENT TO COMPLIANCE.  \n4.1 General Policy. No Covered Person shall (i) engage in any activity inconsistent with, or a violation of, the anticorruption laws and regulations covered by this Policy, nor to authorize, direct, or condone such conduct by anyother Covered Person; (ii) accept, demand or solicit, or be expected to provide, any bribe or other undue advantage; or  \n(iii) use subcontracts, purchase orders, agreements, arrangements, or other vehicles as means of channeling payments to a public official or to a business associate or close family relative of a public official. The FCPA also requires U.S. companies to keep accurate and complete books and records and to maintain proper internal accounting controls.  \n4.2 Reporting Demands for a Bribe. All people and entities that conduct business with Thermo Fisher must understand that Covered Persons will not, under any circumstances, offer, give or accept bribes or kickbacks. Any demand for a bribe or payment of a bribe must be immediately brought to the attention of your Group General Counselor Thermo Fisher General Counsel, who may be contacted by phone or email.  \n5.0 SUMMARY OF FCPA  \n5.1 Anti-bribery Provisions. The FCPA's anti-bribery provisions criminalize giving or offering to give“anything of value” to a foreign official to secure an improper advantage. These provisions have broad reach. They apply to practically any U.S. company and many foreign companies doing business in the United States. Corrupt payments can include \"anything of value,\" including gifts and entertainment. Companies and individuals may be held liable for bribes paid by employees, subsidiaries, third-party agents, and contractors. The meaning of \"foreign officials\"has also been interpreted broadly to include not only government employees and political party officials, but also  \nmilitary personnel, candidates for political office, and employees of","cbCaieRA4HsFZ8Vq","https://ap.wps.com/l/cbCaieRA4HsFZ8Vq","pdf",667792,"English","# Anti-Bribery Compliance Policy\n## Introduction\n## Purpose\n## Scope\n## Commitment to Compliance\n## Summary of FCPA\n## Summary of UK Bribery Act","[{\"question\":\"Who does this Anti-Bribery Compliance Policy apply to?\",\"answer\":\"The policy applies to Thermo Fisher’s worldwide operations, including divisions and subsidiaries, and to directors, officers, and employees (including temporary employees and contractors), as well as relevant distributors and business partners. All such individuals and entities are treated as “Covered Persons.”\"},{\"question\":\"What actions are prohibited under the policy?\",\"answer\":\"Covered Persons must not engage in activities inconsistent with anti-corruption laws, accept or solicit bribes or undue advantages, or use contracts and payment vehicles to channel money to public officials or close family members of officials. It also prohibits authorizing or condoning prohibited conduct.\"},{\"question\":\"How does the policy address reporting of bribery demands?\",\"answer\":\"Any demand for a bribe or payment of a bribe must be immediately brought to the attention of the Group General Counsel / Thermo Fisher General Counsel, available by phone or email. The policy emphasizes that bribes and kickbacks will not be offered, given, accepted, or tolerated.\"}]","Anti-Bribery and Anti-Money Laundering Compliance Policy - Effective Date June 9, 2022 | PDF",1789580045]