Uber discloses its bribery and corruption risk

“Our activities in certain countries with high levels of corruption enhance the risk of unauthorized payments or offers of payments by drivers, consumers, restaurants, shippers or carriers, employees, consultants, or business partners in violation of various anti-corruption laws, including the FCPA, even though the actions of these parties are often outside our control,” Uber stated in its Form S-1. The filing was first reported by FCPA Tracker.

Uber added that its acquisition of Careem, a transportation network company based in Dubai, “may further enhance this risk, because users of Careem’s platform and Careem’s employees, consultants, and business partners may not be familiar with, or currently subject to, these anti-corruption laws,” Uber stated. After the acquisition, Uber said it plans to provide “significant training to Careem’s employees, consultants, and business partners.”

“However, our existing and future safeguards, including training and compliance programs to discourage these practices by such parties, may not prove effective, and such parties may engage in conduct for which we could be held responsible,” Uber added. “Additional compliance requirements may compel us to revise or expand our compliance program, including the procedures we use to verify the identity of platform users and monitor international and domestic transactions.”

Uber said in May 2017 and August 2017 it received requests from the Department of Justice concerning allegations of “small payments to police in Indonesia and other potential improper payments in other countries in which we operate or have operated, including in Malaysia, China, and India.” This investigation remains ongoing. Uber said it is cooperating in the investigation.