Effective Date: 7-FEB-2012
The Foreign Corrupt Practices Act ("FCPA") is a United States federal law that applies
to Medpace and its international subsidiaries. The UK Anti-Bribery Act also applies to Medpace
and its subsidiaries. All Medpace companies around the world potentially fall within the scope
of these laws.
Anti-Bribery and Corruption Policy
The FCPA and the UK Anti-Bribery Act prohibit companies or individuals from directly or
indirectly making payments or offering anything of value to government officials or private
individuals for the purpose of influencing any official act or decision, or encouraging or
discouraging any action in violation or any legal duty, to secure an improper business advantage.
Medpace is committed to full compliance with the FCPA and the UK Anti-Bribery Act.
Medpace strictly prohibits making any payments or providing gifts or anything of value to a
government official or private individual to influence an official act or decision or to induce
the person to do or not do anything in violation of the person's legal duty, in order to gain
a business advantage. This includes any payments, gifts or favors, using Medpace funds or personal
funds, by any Medpace employee, or by any third party on behalf of Medpace or a Medpace employee.
Government official includes anyone who is an officer, employee or representative of a government
of any country, or a state-owned entity including, for example, government-owned or controlled hospitals
or physicians, or members of agencies or committees performing government functions such as granting,
withholding or withdrawing regulatory approvals, licenses and permits.
In order to ensure compliance with the law, it is essential that Medpace financial records accurately and
fairly reflect all corporate transactions, no matter how small. Recording any payments, gifts or other
expenditures in any way that would conceal their true nature, the recipient, or the amount is also a violation
of this policy. No undisclosed or unrecorded funds or assets of Medpace are to be established for any purpose.
Enforcement of this Policy
- The Medpace Corporate Compliance Officer, acting on behalf of and under the authority of the company's
Board of Directors, is responsible for the enforcement of this policy. The Corporate Compliance Officer works
with management to develop, implement, maintain and monitor appropriate policies and procedures which support
compliance, inform Medpace employees and contractors of their specific responsibilities under this policy,
monitor for compliance, and address any non-compliance. The Corporate Compliance Officer periodically reports on
these efforts to the Board of Directors.
- Violation of the law on which this policy is based can subject Medpace and its Board of Directors, management and
employees to prosecution, criminal fines and imprisonment. All employees are accountable for their actions and are
required to report any actual or suspected violations of this policy to the Corporate Compliance Officer. Managers are
ultimately responsible for ensuring the employees they supervise are knowledgeable about and in compliance with this policy,
the FCPA and the UK Anti-Bribery Act. Any employee who violates this policy, or who is aware of it and fails to report conduct
that violates this policy, is subject to disciplinary action including termination and legal action.