Anti-Corruption and Bribery Policy

WE COMPLY WITH ANTI-CORRUPTION LAWS 

Anti-corruption and bribery laws apply to our business activities around the world. These laws are complex and the consequences for violations are severe. We comply with the anti-corruption and bribery laws of the countries in which we do business. 

Bribery 

A “bribe” is generally anything of value, including gifts, meals, entertainment, travel, and other hospitality, that is given in an attempt to improperly influence the recipient’s actions or decisions. We cannot offer or accept a bribe, or “kickback,” as a reward for making or fostering business arrangements. This is not allowed whether done directly or indirectly through a third party. 

Government Officials 

Dealings with government officials require increased care. You should never provide anything of value to a government official in return for an official action. There are specific laws that prohibit bribes or attempts to bribe government officials, employees of entities in which a government has a controlling or ownership interest, political party officials, or candidates for public office. Many governments are taking steps to combat corruption and many countries have specific, rigorous laws against it. If you interact with government officials, be sure to review all applicable policies. Raise any questions promptly with your supervisor or the Legal Department. 

Third Parties 

We do not hire third parties to do something we ourselves are not allowed to do. Our agents and consultants are held to the same rules that we are. For example, the Company may be liable for indirect payments even if we do not know, but should know, that the payment is being made to influence a business action or decision. For more information about anti-corruption and bribery refer to the Anti-Bribery and Corruption Policy and the section of the Code above titled “Gifts and Entertainment.”