Commitment to Ethical Conduct and Anti-Corruption Compliance
ADM is committed to doing business with integrity. This means avoiding corruption in all forms, including bribery. We abide by all applicable anti-corruption laws, including the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act and local laws in every country in which we do business.
ADM has an Anti-Corruption Program intended to provide a level of awareness about anti-corruption laws in order to avoid inadvertent violations of the law and to enable employees to recognize potential issues in time for these to be addressed appropriately. Our Anti-Corruption Program encompasses compliance procedures and key controls designed to minimize the potential for corruption in ADM’s global business dealings. The Anti-Corruption Program protects the company from anti-corruption risks in the context of:
- Commercial transactions with government entities and government employees;
- Hosting and gifting provided to government entities and government employees;
- Government tenders and private tenders;
- Hiring current or former government employees;
- Due diligence on third parties with which ADM does business;
- Donations and contributions;
- Political contributions;
- Commercial bribery and extortion;
- Due diligence in the context of mergers, acquisitions, joint ventures and investments;
- Anti-corruption training;
- Anti-corruption auditing;
- Anti-corruption monitoring; and
- Maintaining accurate books and records.