Building Trust Around the World

No Tolerance for Bribery or Corruption

As a global business that always does the right thing, we must never seek unfair advantage through improper payments of any kind.

Flex prohibits bribery, kickbacks and improper payments in any form. We are all expected to comply with all applicable anti-bribery and anticorruption laws, wherever we do business. These include the U.S. Foreign Corrupt Practices Act (FCPA) and the U.K. Bribery Act 2010.

We prevent bribery and other forms of corruption when we:

  • Never offer, promise or give anything of value to anyone to influence any business decision
  • Never employ a third party (such as a consultant, agent or business partner) to make any payment we wouldn’t make ourselves
  • Never accept anything of value to influence a business decision
  • Exercise extra caution when dealing with governments and government officials
  • Contact the Legal Department before responding to any inquiries from government entities

What are bribes, kickbacks and facilitation payments?

A “bribe” is anything of value. It can be cash, gifts, entertainment or business courtesies. A bribe is given with the intent to improperly influence another’s actions or business decisions.

A “kickback” is the payment of money or anything of value as a reward for giving business or an improper business advantage.

“Facilitation payments” are usually of a small amount. They are made to government officials to secure or expedite a routine, nondiscretionary government action. Facilitation payments are prohibited at Flex.

What if an employee is forced to make or accept a payment under duress?

Duress payments do not violate this policy. An employee should report any demands for duress payments before making them. If this is not possible, a report must be made as soon as feasible, using any of our reporting resources.


Government officials

Our business dealings often involve governments around the world. When working with governments and government officials, we must be extra cautious. Corrupt practices with government officials can do serious harm to Flex’s reputation and lead to severe penalties. Any and all contracts with a government entity or official must be reviewed and approved by the Legal Department. The same is true for any gifts or entertainment Flex plans to provide to government officials. Pre-approvals are obtained using the Gifts & Amenities Approval Tool.

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