Diligence Against Corruption Is Everyone

A Message to Cisco Employees

More than ever, nations around the world are enacting new laws and cooperating with each other to fight corruption. The change is driven by growing recognition that corruption inhibits economic growth and limits nations' development potential. Companies like Cisco are expected to police their operations to make sure anticorruption laws are observed.

This means that all of us need to be aware of the broader regulatory scope and potential risks. The things that count as bribery are more than what you might think. And the rules apply around the world, even in countries where corruption seems deep-seated.

It's Not Just the United States

Historically, companies have focused on the 35-year-old Foreign Corrupt Practices Act (FCPA) in the United States. But as business becomes more global, similar laws have been enacted over the last several years in the United Kingdom, Russia, China, India, Taiwan, Brazil, and Spain, among other countries.

In addition, there are global and regional anticorruption conventions by groups such as the United Nations, OECD, and African Union. Employees can't be expected to know all these laws, but Cisco has updated its Global Anti-Corruption Policy (with helpful FAQs) and Code of Business Conduct to reflect the expanding global regulations.

It's Not Just Government Officials

Anticorruption laws extend to government-owned or government-related organizations such as NATO and the World Health Organization. In some countries, there are government-owned airlines, utilities, schools and universities, and other businesses. Certain international laws also cover bribery with commercial and private organizations.

It's Not Just Cisco

Third parties count, too. Cisco cannot condone or assist a partner or intermediary making bribes on our behalf for our business.

It's Not Just "Cash in an Envelope"

A bribe can be anything of value, such as gift certificates, sports tickets, travel accommodations, home repairs or other services, employment offers, charitable donations, and special discounts. Legally speaking, the bribe does not have to be provided to be a violation. Just offering a bribe is enough to break the law.

When Is it an Acceptable Business Gift?

The key factor is reciprocation. While the anticorruption laws and policies around the world have different criteria, the common core difference between acceptable business gifts and entertainment versus bribery is "reciprocation," meaning something is given with the expectation of getting something back. It's also known as "quid pro quo."

The first step when thinking about the appropriateness of giving or accepting a business gift, entertainment, or other favor or hospitality is the intention behind it. If something is given to get something specific in return (such as obtaining or retaining business), it's not a gift.

If you have questions or need assistance, you can confidentially contact the Cisco Legal team at or Cisco's Ethics Office (including options for reporting anonymously).

Cisco is committed to doing business ethically. Thanks for your daily commitment to help Cisco lead with integrity.

Mark Chandler
SVP, Legal Services and General Counsel, Office of the General Counsel