Global Compliance

Charitable giving is as an area that may sometimes appear to be a favor for a Government Official or Health Care Professional. The VRF relies on individuals, including doctors, for certain types of advice and services necessary to fulfill its mission. In certain circumstances, the VRF may compensate individual Government Official or HCP for bona fide consulting and personal services. 

Therefore the VR Foundation is committed to complying with the anti-corruption laws in all countries in which it finances projects or otherwise participates. This includes, but is not limited to, laws in the United States such as the Medicare and Medicaid Patient Protection Act of 1987 (the “Anti-Kickback Statute”), Stark Laws, Federal False Claims Law, the United States Foreign Corrupt Practices Act (the “FCPA”), the Canadian Corruption of Foreign Officials Act and the United Kingdom Bribery Bill 2009 and anti-bribery legislation enacted by each signing country in accordance with the Organization for Economic Co-operation and Development Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (the “OECD Convention”).

VR Foundation prohibits all improper payments of any nature including payments to third parties, Government Officials, Health Care Professionals anywhere in the world.  Additionally, the VRF has zero-tolerance policy to fraudulent, corrupt, collusive or coercive actions that have occurred in projects financed through its awards and grants.  

These policies are applicable to all VR Foundation employees and agents, including all directors, officers, board members and any other individual or entity acting for or on behalf of VR Foundation, anywhere in the world.

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