You should consult your legal or compliance teams, who can help you navigate this tricky area of the law.I noticed there are two references in "in good faith" in the whistleblower clause.So assuming your definition of cultural fit relates to business criteria -- then you determine whether the person has the skills/experience to do a good job and then you evaluate whether the person has the same values and work philosophy as other team members.

The decision to NOT charge for services/products should be business decision based on what makes business sense.

It would not be an ethical decision if there's authority to make that decision. First your team needs to define which traits determine a "cultural fit." Ideally, cultural fit can be boiled down to a set of values and philosophy about work.

So proving that you did not intend to influence the official may be very hard.

Also, violations of the accounting and record keeping provisions do not require any showing of intent.

Janine Yancey A complaint does not have to be written and signed to be valid and trigger HR action.

If an employee makes a verbal harassment complaint, then the HR professional should initiate some type of neutral investigation into the complaint.Some questions for you: Is this an internal site or a public site?Also, are co-workers discussing the post in the workplace?The FCPA does create exceptions to the rule against making payments for certain kinds of payments. However, the definition and application of what constitutes a permitted facilitation payment is very tricky.It is not something that you should handle on your own.Mike Koehler The “BRIC” countries have been identified as having a history or business culture in which corruption is an issue. It is important to note, however, that bribery is a global issue and is not limited to these countries.