GIFT, ENTERTAINMENT, THIRD-PARTY TRAVEL AND CHARITABLE CONTRIBUTION POLICY
|
|
- Clyde Preston
- 7 years ago
- Views:
Transcription
1 GIFT, ENTERTAINMENT, THIRD-PARTY TRAVEL AND CHARITABLE CONTRIBUTION POLICY SCOPE This policy applies to the operations of Oceaneering International, Inc. and its subsidiaries and other affiliated companies ( Oceaneering or the Company ) anywhere in world. All directors, officers, members, managers and employees (permanent and temporary) of the Company, and any agents or other persons or entities with authority to act on its behalf, (collectively Company Representatives ) must comply with this policy. This policy supplements and should be read in conjunction with the Company s Code of Business Conduct and Ethics, Anti-Corruption Compliance Policy and related policies and procedures (altogether, the Code of Conduct ). POLICY Company Representatives may Provide to and receive from Third Parties Gifts, Entertainment and Travel, and make Charitable Contributions, only in accordance with the Code of Conduct, including this policy. Accordingly, neither Oceaneering nor any Company Representative may Provide any Gift, Entertainment, Travel or Charitable Contribution with the intent to exert improper influence over the recipient, induce the recipient to violate his or her duties, secure an improper advantage for Oceaneering or improperly reward the recipient for past conduct. All Gifts, Entertainment, Travel, and Charitable Contributions Provided to a Third Party, and any requests for authorization of the same must be fully and accurately documented and recorded in the books and records of Oceaneering as more fully set forth in this policy. No person subject to this policy will suffer adverse consequences for refusing to Provide any Gift, Entertainment, Travel or Charitable Contribution which does not comply with this policy, even if so doing results in the loss of business to Oceaneering. This policy shall be reviewed regularly and may be updated from time to time. Definitions For purposes of this policy: Charitable Contribution means a contribution of anything of value, including, but not limited to, cash, a cash equivalent, other property or use of Company resources, such as facilities, supplies, computers or employee time during working hours, and purchasing tickets to fundraising events, solely to or for the use of not-for-profit organizations or associations for a charitable purpose; 1
2 Entertainment includes meals, cultural events, sporting events and the like Provided for or by a Third Party. If the recipient does not attend the meal or event with the party Providing the same, it is a Gift; FCPA means the United States Foreign Corrupt Practices Act of 1977, as amended; Gift includes anything of value other than Entertainment or Travel, whether in the form of goods or services, Provided for or by a Third Party, voluntarily and without bargain, inducement or compensation, and, including, but not limited to, an in-kind gift such as the use of Oceaneering assets or facilities or a Company Representative s vacation home or other property. A meal or event that the recipient does not attend with the party Providing the same is a Gift; Nominal Value means with respect to: any Gift, Travel or Charitable Contribution having a value of less than U.S. Dollars ( USD ), or equivalent non-usd amount, per recipient per event or occasion; and any Entertainment having a value of less than USD, or equivalent non-usd amount, per recipient per event or occasion; provided, however, that in either case a lower local limit may be established by the Responsible Officer with the concurrence of the General Counsel or his or her designee. Questions regarding the value of a Gift, Entertainment, Travel or Charitable Contribution should be directed to the Regional Controller or a member of the Legal Department. In general, the value of a Gift, Entertainment, Travel or Charitable Contribution will be measured by its cost; however, if a Gift, Entertainment, Travel or Charitable Contribution is provided in kind (for example, the use of a Company facility or resource), the value should reflect the fair market value of the benefit; Private Party means a Third Party who is not a Public Official; Provide means to offer, promise, pay for, give or authorize, whether directly or indirectly; Public Entity means any government or any department, agency or instrumentality thereof, any state-owned or -controlled company or enterprise, the military, any public international organization and any political party; Public Official means any officer or employee of a government or any department, agency or instrumentality thereof, including, but not limited to, an employee of a stateowned or -controlled company, an employee of a public international organization, a political party, a party official or candidate for office, and anyone working in an official capacity for or on behalf of any government or any department, agency or instrumentality 2
3 thereof, as well as anyone who exercises a public function for or on behalf of a country, public agency or public enterprise. Some examples of Public Officials include: employees of national oil companies; members of royal families; members of the military; employees of state-owned universities; employees of the World Bank, the United Nations, the European Union and the International Monetary Fund; and immigration and customs officials. Public Officials include all levels and all ranks of government officials, whether federal, state, provincial, county, municipal or other level; Regional Legal Counsel means any regional in-house legal counsel or the General Counsel of Oceaneering; Responsible Controller means the regional controller of the relevant business line, relevant worldwide controller, Chief Financial Officer or Executive Vice President; Responsible Officer means the Chief Executive Officer, Chief Operating Officer, Executive Vice President, or Vice President or Senior Vice President of the relevant business line, region/country or function; Third Party means anyone not employed by Oceaneering, including anyone who is involved in obtaining, performing or retaining business for Oceaneering, and any Public Official. Some examples of Third Parties include: customers; subcontractors; vendors/suppliers; consultants and other service providers; intermediaries such as agents, brokers and business development representatives; business partners; Public Entities; and the respective directors, officers, employees, members, officials and representatives of the foregoing; Travel means any travel which is Provided for or by a Third Party; and UKBA means the United Kingdom s Bribery Act of 2010 (including as it may be amended). GENERAL PRINCIPLES In general, a Gift, Entertainment, Travel or Charitable Contribution to a Third Party should not be Provided (whether or not advance approval is required as specified below) unless it: is lawful under the written laws of the country where it is Provided; does not violate the FCPA or other anti-corruption laws which may apply, such as the UKBA, or Oceaneering s Anti-Corruption Compliance Policy; is not Provided, explicitly or implicitly, in exchange for something in return; may permissibly be received by the recipient; 3
4 does not exceed the amount authorized pursuant to this policy; is reasonable and appropriate for the intended purpose or occasion such that, at a minimum, public disclosure of it would not embarrass the recipient or the Company; is fairly disclosed, correctly and accurately documented, and properly recorded in the Company s books and records; and otherwise complies with the standards and requirements of Oceaneering s Code of Conduct, including this policy. GIFTS AND ENTERTAINMENT Appropriate Gifts and Entertainment In general, Providing a Gift or Entertainment to a Third Party is appropriate (whether or not advance approval is required as specified below) when it is consistent with the General Principles set forth above and: is intended only to establish or maintain good business relations or offer normal courtesy; is consistent with generally accepted business practices and ethical standards of the country where the Gift or Entertainment is Provided; is allowed by the recipient s employer and/or any Public Entity which owns or controls the recipient s employer (as the case may be); and has a reasonable value in absolute and relative terms, including the organizational level and status of the recipient and the norms of the country in which it is Provided. Gift and Entertainment Limits No specific maximum value is established for Gifts or Entertainment; however: any Gift or Entertainment should meet all general requirements listed under the heading Appropriate Gifts and Entertainment above, as well as any criteria established in the Categories of Gifts and Entertainment section below; the Gifts or Entertainments should not be of such frequency or aggregate in such a manner that the total amount is, or could be, interpreted as unreasonable or inappropriate; and advance approval is required to Provide a Gift or Entertainment to a Public Official, as described under the Permissible with Advance Approval heading below. 4
5 Categories of Gifts and Entertainment Usually Permissible without Advance Approval: Gifts and Entertainment which are Provided to Private Parties and are modest, infrequent and of Nominal Value do not require advance approval under this policy and may be given at the discretion of the Company Representative as authorized. These are typically: Gifts of promotional items bearing a Company trademark, such as umbrellas, caps, pens, calendars, or golf balls; Gifts or Entertainment of Nominal Value to show appreciation; Gifts of event tickets of Nominal Value; Entertainment such as a business meal commensurate with the rank or position of the recipient; and attendance at sporting or entertainment events that allow time for promotion of Oceaneering s capabilities. Gifts Provided to Public Officials and are modest, infrequent and consist solely of promotional items of Nominal Value bearing a Company trademark, such as Companytrademarked umbrellas, caps, pens, calendars or golf balls, do not require advance approval under this policy and may be given at the discretion of the Company Representative as authorized. The Responsible Officer, with the concurrence of the General Counsel or his or her designee, may establish more restrictive limitations within this category. Permissible with Advance Approval A Gift or Entertainment Provided to a Private Party in excess of Nominal Value per recipient must be approved in advance by the Responsible Officer. A Gift or Entertainment Provided to a Public Official is permissible only with advance approval, as follows: Nominal Value Any Gift or Entertainment of Nominal Value per recipient to a Public Official must be approved in advance by the Responsible Officer and Regional Legal Counsel (except Gifts of promotional items of Nominal Value bearing a Company trademark, such as umbrellas, caps, pens, calendars or golf balls); and More than Nominal Value Any Gift or Entertainment in excess of Nominal Value per recipient to a Public Official must be approved in advance by the Responsible Officer and Regional Legal Counsel. 5
6 Never Permissible Gifts and Entertainment are never permissible if they: violate the Company s Code of Business Conduct and Ethics, Anti-Corruption Compliance Policy or any related policy or procedure, including this policy; violate the FCPA or other anti-corruption laws applicable to the jurisdiction of the recipient or Oceaneering, including, but not limited to, the UKBA; create the perception of a violation of the FCPA, UKBA or other anti-corruption laws applicable to the recipient or Oceaneering; are of cash or a cash equivalent, such as a gift card or voucher; have been solicited by the recipient, or are offered, explicitly or tacitly, for something in return; are likely to adversely affect Oceaneering s reputation; or are concealed, hidden or disguised (including being paid for personally by a Company Representative to avoid having to report or seek approval as set forth in this policy). Gifts and Entertainment Provided to Company Representatives Company Representatives may accept Gifts and Entertainment from Third Parties which meet the approval and other requirements for permissible Gifts and Entertainment to Third Parties set forth in this policy. DOMESTIC OR INTERNATIONAL TRAVEL INVOLVING THIRD PARTIES Appropriate Travel In general, paying for or otherwise Providing Travel for Third Parties, including Travel by Public Officials, is appropriate (whether or not advance approval is required below) when it is consistent with the General Principles set forth above and the Travel: is directly related to promotion, demonstration or explanation of Oceaneering s products or services or the execution or performance of a contract, or otherwise has a legitimate business purpose; is not for side trips or family members, or intended as a Gift or Entertainment, for a Public Official; 6
7 is lawful under the written laws of the country(s) where the Travel will occur; complies with policies of each commercial organization and/or Public Entity involved; is paid directly to the service provider or reimbursed by Company check (cheque), wire transfer or other means excluding the use of cash or cash equivalents; and is not offered or Provided to the recipient with the intent of obtaining or retaining business or gaining an improper advantage. Costs which may be paid directly to the Travel provider or reimbursed include airfare, lodging, transportation and meals which comport with the above. Required Approval Travel of Nominal Value Provided for a Private Party does not require advance approval and may be given at the discretion of the Company Representative as authorized. Travel Provided for a Private Party in excess of Nominal Value per recipient must be approved in advance by the Responsible Officer and Regional Legal Counsel. Travel Provided for a Public Official is permissible only with advance approval, as follows: Nominal Value Any Travel of Nominal Value per recipient Provided for a Public Official must be approved in advance by the Responsible Officer and Regional Legal Counsel; and More than Nominal Value Any Travel in excess of Nominal Value per recipient Provided for a Public Official must be approved in advance by the Responsible Officer and the General Counsel. Each Third Party involved should be informed in advance of those costs which the Company will or will not reimburse in accordance with this policy. Travel Provided to Company Representatives Company Representatives may accept Travel from Third Parties which meets the approval and other requirements for permissible Travel Provided for Third Parties set forth in this policy. CHARITABLE CONTRIBUTIONS Commitment to Communities The Company desires to be involved in communities in which its employees live and work. As such, Oceaneering may consider a Charitable Contribution, including in-kind support, that benefits such a community and is consistent with the General Principles set forth above. 7
8 Required Approval A Charitable Contribution of Nominal Value does not require advance approval and may be given at the discretion of the Company Representative as authorized. A Charitable Contribution in excess of Nominal Value may be Provided by Oceaneering, or by any Company Representative on behalf, in the name, or using the resources, of Oceaneering, only if approved in advance as follows: Regional Approval for a request to Provide a Charitable Contribution up to a limit of 1,000 USD per event/occasion, or equivalent non-usd amount, per recipient, the Responsible Officer and Responsible Controller must approve the request; and Corporate Approval for a request to Provide a Charitable Contribution in excess of such amounts, the Chief Executive Officer, in addition to Responsible Officer and Responsible Controller, must approve the request. BOOKS AND RECORDS Approvals All requests of a Company Representative for authority required by this policy to Provide Gifts, Entertainment, Travel or Charitable Contributions or to accept Gifts, Entertainment or Travel must be submitted in writing, documented in reasonable detail and approved in writing. Subject to the following paragraph, a request or approval required by this policy to be in writing may be by or otherwise in electronic form. The form and content of any required approval or request may be established by the Chief Financial Officer and the General Counsel from time to time, and include at a minimum identification of each Company Representative, Public Official or other Third Party involved, any related Public Entity, company or other entity or association, the business purpose and, in the case of Travel, the origin, destination, class of service and other relevant details of each traveler. If the requesting Company Representative is the Responsible Officer, the Company Representative may self-approve the transaction, subject to any required approval by Regional Legal Counsel or the General Counsel, but must record the information required above. For convenience, a matrix summarizing the approvals required by this policy is attached as Appendix 1. Expensing, Recording and Accounting The following, if Provided by a Company Representative in compliance with this policy and properly recorded, may be reimbursed on employee expense reports: 8
9 Gifts, Entertainment and Third-Party Travel; and Charitable Contributions up to a limit of 1,000 USD per event/occasion, or equivalent non-usd amount, per recipient. Charitable Contributions in excess of the limits above may not be reimbursed on employee expense reports, unless approved in advance by the Chief Financial Officer. Any Gift, Entertainment, Travel or Charitable Contribution Provided by Oceaneering, or by any Company Representative on behalf, in the name, or using the resources, of Oceaneering, along with any request for or approval thereof, must be recorded and documented in reasonable detail and retained in accordance with the Company s records retention policy. All expenditures for Gifts, Entertainment, Travel or Charitable Contributions must be properly coded and expensed in accordance with Company guidelines established by the Chief Financial Officer. AUDITS Compliance with this policy is subject to audit. All Company Representatives shall cooperate in such audits as requested. PENALTIES AND SANCTIONS Failures to comply with this policy may result in severe fines, imprisonment and other sanctions against the Company, other entities and the individuals involved. Appropriate action will be taken by the Company against any Company Representative who violates this policy, up to and including dismissal or equivalent action. LOCAL CUSTOMS AND PRACTICES All Company Representatives must follow this policy, even if it conflicts with local customs or practices. EXCEPTIONS Any exception to this policy must be approved in advance by the General Counsel. FURTHER INFORMATION Please direct any questions regarding this policy to your Regional Controller or a member of the Legal Department. 9
10 Appendix 1 GIFTS, ENTERTAINMENT, THIRD-PARTY TRAVEL AND CHARITABLE CONTRIBUTIONS Approvals Required 1 Gifts Entertainment Travel Involving Third Parties Charitable Contributions EXCEPTIONS Any amount GC Nominal Value 2 Non-Pub None 3 Pub RO & RLC 4 Non-Pub None 3 Pub RO & RLC Non-Pub None 3 Pub RO & RLC None In excess of Nominal Value Non-Pub RO Pub RO & RLC Non-Pub RO Pub RO & RLC Non-Pub RO Pub RO & RLC Up to $1k ea. RO & RC Over $1k ea. CEO 5 Key: GC General Counsel Pub Public Official (as defined in policy) 6 RC Responsible Controller (regional controller of the relevant business line, relevant worldwide controller, CFO or EVP) RLC Regional Legal Counsel (in-house regional legal counsel) or GC RO Responsible Officer (VP/SVP of the relevant business line, function or country/region, EVP, COO or CEO) 1 The RO, with the GC s concurrence, may impose more restrictive limits than those set forth in this matrix. 2 Nominal Value" means having the following cost or calculated in-kind value with respect to: (i) Gifts, Third-Party Travel and Charitable Contributions less than US$200 (or non-usd equiv.) per recipient per event/occasion, and (ii) Entertainment less than $400 (or non-usd equiv.) per recipient per event/occasion; provided the RO with concurrence of GC or his or her designee may set a lower limit. 3 If otherwise compliant with policy, e.g., lawful and not unreasonable or inappropriate, and within financial authority. 4 Except Company-trademarked promotional items of Nominal Value. 5 Not reimbursable through employee expense process. Must be processed through Accounts Payable process. 6 Public Official includes any officer or employee of a government or any department, agency or instrumentality thereof, an employee of a public international organization, political party or official, candidate for office, and anyone working in an official capacity or having a public function, such as a NOC employee, member of a royal family, member of the military, or an immigration or customs official. Gift, Entertainment, Third-Party Travel and
LANTHEUS HOLDINGS, INC. Foreign Corrupt Practices Act and Anti-Bribery Compliance Policy
LANTHEUS HOLDINGS, INC. Foreign Corrupt Practices Act and Anti-Bribery Compliance Policy 1. Introduction. Applicability. This Foreign Corrupt Practices Act and Anti-Bribery Compliance Policy (this Policy
More informationPlatform Specialty Products Corporation Foreign Corrupt Practices Act/Anti-Corruption Policy
1. Introduction. Platform Specialty Products Corporation Foreign Corrupt Practices Act/Anti-Corruption Policy 1.1 Combating Corruption. Platform Specialty Products Corporation, including its subsidiaries,
More informationANTI BRIBERY AND FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY
ANTI BRIBERY AND FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY THIS POLICY DOES NOT CREATE A CONTRACT OF EMPLOYMENT OR ALTER THE AT WILL NATURE OF ANY EMPLOYEE S EMPLOYMENT IN ANY WAY. 1. Statement of
More informationCorporate Code of Conduct
Corporate Code of Conduct Statement of Policy. It is the policy of Casa Mining Limited (the "Company") that all of its officers, directors, employees, contractors, consultants and agents representing the
More informationAnti-Corruption and FCPA Compliance Policy
Anti-Corruption and FCPA Compliance Policy Purpose and Scope Vicor Corporation ( Vicor or the Company ) must comply with the U.S. Foreign Corrupt Practices Act of 1977, as amended (the "FCPA") and all
More informationComplying with the U.S. Foreign Corrupt Practices Act
Complying with the U.S. Foreign Corrupt Practices Act 1. About This Manual This Manual describes the Foreign Corrupt Practices Act ( FCPA ), 15 U.S.C. 78m, 78dd, 78ff (collectively, FCPA ), anti-corruption
More informationMANNING & NAPIER, INC. FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY
MANNING & NAPIER, INC. FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY Purpose The purpose of this Foreign Corrupt Practices Act Compliance Policy (this Policy ) is to help ensure compliance by Manning
More informationAdministrative Policy No. AD 2.26 Title:
I. SCOPE: Administrative Policy No. AD 2.26 Page: 1 of 5 This policy applies to all directors, officers, employees, agents, and shareholders of Tenet Healthcare Corporation, its subsidiaries and/or affiliates
More informationGoodyear s Anti-bribery Policy July 1, 2011
Goodyear s Anti-bribery Policy July 1, 2011 Anti-bribery Policy Goodyear does not wish to obtain business advantages by offering or receiving improper payments or anything of value, even in countries where
More informationForeign Corrupt Practices Act Policy August 19, 2015
I. PURPOSE To provide guidelines to all officers, directors, employees, consultants and agents that are employed by the Company to ensure compliance with the Foreign Corrupt Practices Act of the United
More informationING LEASE UK GIFTS, ENTERTAINMENT AND ANTI-BRIBERY POLICY
ING LEASE UK GIFTS, ENTERTAINMENT AND ANTI-BRIBERY POLICY 1 CONTENTS Statement from the Board of ING Lease (UK) Limited POLICY 1. Introduction 2. Objectives 3. Scope 4. Definitions 5. Rules on Gifts and
More informationNCI BUILDING SYSTEMS, INC. FOREIGN CORRUPT PRACTICES ACT POLICY STATEMENT AND COMPLIANCE GUIDE
NCI BUILDING SYSTEMS, INC. FOREIGN CORRUPT PRACTICES ACT POLICY STATEMENT AND COMPLIANCE GUIDE Introduction The Foreign Corrupt Practices Act as amended by the International Anti-bribery and Fair Competition
More informationSTATEMENT FROM THE CHAIRMAN
STATEMENT FROM THE CHAIRMAN In an ever-changing global marketplace, it is important for all of us to have an understanding of the responsibilities each of have in carrying out day-to-day business decisions
More informationSEMGROUP CORPORATION. Anti-Corruption Compliance Policy August, 2011
SEMGROUP CORPORATION Anti-Corruption Compliance Policy August, 2011 SCOPE This is a global policy (the Policy ) applicable to the worldwide operations of SemGroup Corporation ("SemGroup") and all of its
More informationANTI-CORRUPTION AND ANTI-BRIBERY POLICY
COMPLIANCE 18.0 ANTI-CORRUPTION AND ANTI-BRIBERY POLICY I. SCOPE This policy applies to all directors, officers, employees, agents, and shareholders of UHS of Delaware, Inc. (hereafter, UHS ), its subsidiaries
More informationPHILIP MORRIS INTERNATIONAL INC.
PHILIP MORRIS INTERNATIONAL INC. Code of Business Conduct and Ethics for Directors 1. Introduction This Code of Business Conduct and Ethics for Directors ( Code ) has been adopted by Philip Morris International
More informationFOREIGN CORRUPT PRACTICES ACT AND ANTI-CORRUPTION COMPLIANCE POLICY. Adopted April 30, 2014
FOREIGN CORRUPT PRACTICES ACT AND ANTI-CORRUPTION COMPLIANCE POLICY Adopted April 30, 2014 134782_1 TABLE OF CONTENTS I. POLICY STATEMENT... 1 II. KEY TERMS... 2 III. SCOPE AND APPLICABILITY OF THIS POLICY...
More informationHILLENBRAND, INC. AND SUBSIDIARIES. Global Anti-Corruption Policy Statement and Compliance Guide
HILLENBRAND, INC. AND SUBSIDIARIES Global Anti-Corruption Policy Statement and Compliance Guide Hillenbrand, Inc., including all of its subsidiaries (referred to collectively as the Company ), maintains
More informationMUELLER INDUSTRIES, INC. ANTICORRUPTION POLICY
MUELLER INDUSTRIES, INC. ANTICORRUPTION POLICY THIS POLICY HAS BEEN APPROVED BY THE BOARD OF DIRECTORS OF MUELLER INDUSTRIES, INC. ON FEBRUARY 11, 2010 AND IS APPLICABLE TO ALL DIRECTORS, OFFICERS, EMPLOYEES,
More informationLAUREATE ANTI-CORRUPTION POLICY
LAUREATE ANTI-CORRUPTION POLICY Laureate Anti-Corruption Policy 1.0 PURPOSE AND BACKGROUND This Anti-Corruption Policy establishes basic standards and a framework for the prevention and detection of bribery
More informationWorldwide Anti-Corruption Policy
Worldwide Anti-Corruption Policy I. PURPOSE The laws of most countries make the payment or offer of payment or even receipt of a bribe, kickback or other corrupt payment a crime, subjecting both Eaton
More informationERIN ENERGY CORPORATION. ANTI-CORRUPTION COMPLIANCE POLICY Effective Date: 10/1/2011
ERIN ENERGY CORPORATION ANTI-CORRUPTION COMPLIANCE POLICY Effective Date: 10/1/2011 Statement of Policy It is the policy of Erin Energy Corporation, (the Company ) to conduct its worldwide operations ethically
More informationDIGITAL RIVER, INC. FOREIGN CORRUPT PRACTICES ACT AND ANTI-BRIBERY POLICY. (Adopted by resolution of the Board of Directors on December 1, 2011)
DIGITAL RIVER, INC. FOREIGN CORRUPT PRACTICES ACT AND ANTI-BRIBERY POLICY (Adopted by resolution of the Board of Directors on December 1, 2011) Digital River, Inc. and our affiliates ( DR ) must comply
More informationMACLEAN-FOGG COMPANY FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY
MACLEAN-FOGG COMPANY FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY MacLean-Fogg s corporate policy prohibits all improper or unethical payments to government officials anywhere in the world. This is
More informationAmgen GLOBAL CORPORATE COMPLIANCE POLICY
1. Scope Applicable to all Amgen Inc. and subsidiary or affiliated company staff members, consultants, contract workers and temporary staff worldwide ( Covered Persons ). Consultants, contract workers,
More informationNewYork-Presbyterian Hospital Sites: All Centers Hospital Policy and Procedure Manual Number: C150 Page 1 of 10
Page 1 of 10 TITLE: POLICY AND PROCEDURES REGARDING COMPLIANCE WITH THE FOREIGN CORRUPT PRACTICES ACT ( FCPA ) POLICY: All Hospital Personnel are responsible for complying with the U.S. Foreign Corrupt
More informationMATTHEWS INTERNATIONAL CORPORATION
MATTHEWS INTERNATIONAL CORPORATION U.S. FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY INTRODUCTION Principles Underlying the United States Foreign Corrupt Practices Act ( FCPA ). The FCPA s Anti-Bribery
More informationAnti-Bribery and Corruption Policy
Newcrest strictly prohibits bribery and other unlawful or improper payments made to any individual or entity, as outlined in this Anti-Bribery & Corruption Policy. Newcrest's Anti- Bribery & Corruption
More informationFOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY
FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY Acuity Brands, Inc. is committed to maintaining the highest level of ethical and legal standards in the conduct of our business activities. The Company s
More informationExhibit B SUMMIT ESP, LLC POLICY RELATED TO COMPLIANCE WITH THE UNITED STATES FOREIGN CORRUPT PRACTICES ACT
Exhibit B SUMMIT ESP, LLC POLICY RELATED TO COMPLIANCE WITH THE UNITED STATES FOREIGN CORRUPT PRACTICES ACT Summit ESP, LLC and any related companies (collectively Summit ) will conduct its business transactions
More informationELEPHANT TALK COMMUNICATIONS CORP. FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY
ELEPHANT TALK COMMUNICATIONS CORP. FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY I. POLICY STATEMENT This Foreign Corrupt Practices Act Compliancy Policy (the Policy ) has been adopted by Elephant Talk
More informationTitle: Gifts and Business Courtesies
Title: Gifts and Business Courtesies Effective Date: 5/04; Rev. 5/07 POLICY: Employees, (referred to as associates at some affiliates) officers and members of the Boards of Directors of Iowa Health System
More informationCOMPLIANCE POLICY MANUAL
COMPLIANCE POLICY MANUAL FOREIGN CORRUPT PRACTICES ACT 07/24/2012 Policy Number 16-100 SUBJECT: FOREIGN CORRUPT PRACTICES ACT Application: Worldwide Strategic Business Units and Subsidiaries. It is the
More informationMIDMARK CORPORATION FCPA COMPLIANCE POLICY
MIDMARK CORPORATION FCPA COMPLIANCE POLICY I. INTRODUCTION The purpose of this guide is to provide all Midmark Corporation teammates an overview of the Foreign Corrupt Practices Act (FCPA) and its application
More informationCARDINAL RESOURCES LLC INTRODUCTION
CARDINAL RESOURCES LLC ANTI- BRIBERY AND ANTI- CORRUPTION POLICY INTRODUCTION The purpose of this Anti- bribery and Anti- corruption Policy (the "Policy") is to ensure compliance by the Red Bird Group
More informationHOWARD UNIVERSITY POLICY
HOWARD UNIVERSITY POLICY Policy Number: 400-007 Policy Title: CONDUCTING GLOBAL BUSINESS IN COMPLIANCE WITH FOREIGN CORRUPT PRACTICES ACT Responsible Officer: General Counsel and Chief Compliance Officer
More informationUnclassified. BG Group Standard. Hosting of Public Officials BG-ST-LEG-ECCU-006
Unclassified BG Group Standard Hosting of Public Officials BG-ST-LEG-ECCU-006 Document and Version Control Version Author Issue Date Revision Detail 1.0 Head of Ethical Conduct 01 July 2011 This Standard
More informationPioneer Power Solutions, Inc. Code of Business Conduct and Ethics
A. INTRODUCTION Pioneer Power Solutions, Inc. Code of Business Conduct and Ethics The purpose of this Code of Business Conduct and Ethics (this Code ) is to describe standards of conduct and business expected
More informationHow To Ensure That Gifts And Hospitality Are Not Considered A Bribe
POLICY DOCUMENT Prepared by the ICC Commission on Corporate Responsibility and Anti-corruption Summary: Introduction Definitions of terms used in these Guidelines Guidelines VS/zse - 26 June 2014 A. Introduction
More informationCHARTER FOR THE THE REGULATORY, COMPLIANCE & GOVERNMENT AFFAIRS COMMITTEE CHARTER THE BOARD OF DIRECTORS
CHARTER FOR THE THE REGULATORY, COMPLIANCE & GOVERNMENT AFFAIRS COMMITTEE CHARTER OF THE BOARD OF DIRECTORS OF Copyright/permission to reproduce Materials in this document were produced or compiled by
More informationEAGLE PARENT, INC EPICOR SOFTWARE CORPORATION ACTIVANT SOLUTIONS, INC. FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY. (As Adopted - July 2011)
EAGLE PARENT, INC EPICOR SOFTWARE CORPORATION ACTIVANT SOLUTIONS, INC. FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY (As Adopted - July 2011) 1.0 FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY ( FCPA
More informationSupplier Anti-Corruption and Anti- Bribery Policy
Supplier Anti-Corruption and Anti- Bribery Policy 2014 Dwellworks Contents Purpose and Scope... 3 Core Principles... 4 Guidelines for Anti-Corruption and Anti-Bribery Compliance... 5 Applicable Definitions...
More informationANTI-BRIBERY. Table of Contents Page #
Responsible University Official: Vice President for Finance Operations and Treasurer Responsible Office: Office of Financial Operations Origination Date: March 31, 2015 ANTI-BRIBERY Policy Statement Northwestern
More informationGroup Anti-Corruption Compliance Policy. 20-OCT-2012 2509-MI60-00P1-0007 1 of 15 MODEC GROUP POLICY REVISION HISTORY
Document Title: Group Anti-Corruption Compliance Policy Version Date Policy Category Page 20-OCT-2012 1 of 15 MODEC GROUP POLICY Ver Status Date Originator Reviewer Approver 1 Final 10/20/2012 M. Lipowski
More informationCompliance with the Foreign Corrupt Practices Act
l Compliance with the Foreign Corrupt Practices Act Howard O. Weissman Vice President and Associate General Counsel-International Lockheed Martin Corporation Foreign Corrupt Practices Act U.S. statute
More informationEAGLE PARENT, INC EPICOR SOFTWARE CORPORATION ACTIVANT SOLUTIONS, INC. UK ANTI-BRIBERY AND CORRUPTION POLICY. (As Adopted July 2011)
EAGLE PARENT, INC EPICOR SOFTWARE CORPORATION ACTIVANT SOLUTIONS, INC. UK ANTI-BRIBERY AND CORRUPTION POLICY (As Adopted July 2011) Introduction This UK Anti-Bribery and Corruption Policy ( Policy ) is
More informationCorporate Code of Conduct
1. Background Corporate Code of Conduct 1.1. For over a century, the Swire group of companies has been recognised as acting responsibly in the course of achieving its commercial success. Our reputation
More informationANTI-BRIBERY AND FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY
Issued: November 12, 2013 ANTI-BRIBERY AND FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY SCOPE This policy applies to all Magnetek, Inc. ( Magnetek ) employees, its subsidiaries and affiliates worldwide,
More informationForeign Corrupt Practices Act Summary and Policy
I. Introduction/Overview Foreign Corrupt Practices Act Summary and Policy It is the policy of Cantel Medical Corp. and its subsidiaries (the Company ) to comply with all applicable laws, rules and regulations,
More informationDRAFT. Anti-Bribery and Anti-Corruption Policy. Introduction. Scope. 1. Definitions
DRAFT Change History: Anti-Bribery and Anti-Corruption Policy Control Risks Group Ltd Commercial in confidence Introduction This document defines Control Risks policy on the avoidance of bribery and corruption.
More informationAsterias Biotherapeutics, Inc. Code Of Business Conduct And Ethics. March 10, 2013
Asterias Biotherapeutics, Inc. Code Of Business Conduct And Ethics March 10, 2013 This Code of Business Conduct and Ethics (the "Code") sets forth legal and ethical standards of conduct for directors,
More informationANTI-BRIBERY AND CORRUPTION POLICY
ANTI-BRIBERY AND CORRUPTION POLICY OBJECTIVES Woodside is committed to conducting its business and activities with integrity. To achieve this objective: Woodside will not engage in corrupt business practices;
More informationBB&T CORPORATION CODE OF ETHICS FOR DIRECTORS
I. STATEMENT OF GUIDING PRINCIPLES BB&T CORPORATION CODE OF ETHICS FOR DIRECTORS The ultimate success of BB&T Corporation ( BB&T ) is the result of many factors: the vision and strength of the Board of
More informationU.S. Foreign Corrupt Practices Act for Beginners
U.S. Foreign Corrupt Practices Act for Beginners This presentation, related materials and subsequent discussion are provided for educational purposes only. They do not constitute legal advice nor do they
More informationANTI-CORRUPTION POLICY AND PROCEDURES
ANTI-CORRUPTION POLICY AND PROCEDURES EXECUTIVE SUMMARY The nature of the oil, gas and power industries requires STS Consulting Services, LLC ( Company ) to operate in a wide range of legal and business
More informationUr-Energy Inc. Code of Business Conduct and Ethics
Ur-Energy Inc. Code of Business Conduct and Ethics As Amended Effective February 5, 2014 2957409.2 TABLE OF CONTENTS INTRODUCTION... 3 CONFLICTS OF INTEREST... 3 GIFTS, INVITATIONS AND ENTERTAINMENT GUIDELINES...
More informationFOREIGN CORRUPT PRACTICES ACT
FOREIGN CORRUPT PRACTICES ACT FAQs 1. What is the Foreign Corrupt Practices Act (FCPA)? The FCPA is a federal law, enforced by the U.S. Department of Justice, which prohibits payments, gifts, or even offers
More informationAVIATION AUTHORITY POLICY
PURPOSE: To protect the integrity of the Authority by providing a guide for proper conduct of Board members and employees of the Authority, including discipline for violations, and establishing a program
More informationSEKO Logistics Anti-Corruption and Foreign Corrupt Practices Act Policy
SEKO Logistics Anti-Corruption and Foreign Corrupt Practices Act Policy General Policy: SEKO Logistics ( SEKO ) conducts its business ethically and in compliance with all laws in the countries where SEKO
More informationAnti-Bribery and Corruption Policy (including Gifts and Hospitality)
Anti-Bribery and Corruption Policy (including Gifts and Hospitality) Royal Mail Group has a strict zero tolerance policy towards bribery and corruption. This policy sets out the standards of behaviour
More informationForeign Corrupt Practices Act & Compliance Policy
Team Resources Management () INTEGRITY MANAGEMENT SYSTEM (IMS) Printed documents are considered uncontrolled. Controlled documents can be found on the Atlantica server. -2-POL-057 1 0 02-Dec-2013 1 of
More information1. Compliance with Laws, Rules and Regulations
CODE OF BUSINESS CONDUCT - EXAMPLE INTRODUCTION This Code of Business Conduct covers a wide range of business practices and procedures. It does not cover every issue that may arise, but it sets out basic
More informationIntroduction to the Foreign Corrupt Practices Act (a training presentation for employees)
Introduction to the Foreign Corrupt Practices Act (a training presentation for employees) Introduction Thank you for participating in our Foreign Corrupt Practices Act (FCPA) training program. [Our Company]
More informationFOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY
FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY The following guidelines are derived from the United States Foreign Corrupt Practices Act ( FCPA ), and no deviation from these guidelines is permitted.
More informationcode of Business Conduct and ethics
code of Business Conduct and ethics Introduction This document provides information about our Code of Business Conduct and Ethics. All directors, officers and employees are individually and collectively
More informationINNOSPEC INC. ( INNOSPEC ) FOREIGN CORRUPT PRACTICES ACT POLICY INTRODUCTION
INNOSPEC INC. ( INNOSPEC ) FOREIGN CORRUPT PRACTICES ACT POLICY INTRODUCTION The vast majority of countries have adopted anti-bribery laws. Innospec s securities are registered on the NASDAQ in the United
More informationCommand Center, Inc. CORPORATE GOVERNANCE GUIDELINES
Command Center, Inc. CORPORATE GOVERNANCE GUIDELINES These (the Guidelines ) have been adopted by the Board of Directors of Command Center, Inc., to assist the Board and its committees in the exercise
More informationOMNI TECHNICAL SOLUTIONS. Business Ethics, Compliance, Anti-Corruption and Anti-Money Laundering Policy
OMNI TECHNICAL SOLUTIONS Business Ethics, Compliance, Anti-Corruption and Anti-Money Laundering Policy Updated: September 2015 Table of Contents 1. Introduction... 2 2. Business Ethics... 3 2.1 Compliance...
More informationAngard Staffing Gifts and Hospitality Policy
Angard Staffing Gifts and Hospitality Policy Angard Staffing is committed to providing employees with guidance on the giving and receiving of gifts and hospitality so that they remain compliant with the
More informationPHOENIX NEW MEDIA LIMITED FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY
PHOENIX NEW MEDIA LIMITED FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY Phoenix New Media Limited (together with its subsidiaries, the Company ) is committed to conducting all aspects of its business
More informationNyrstar Group Policy: Anti-Corruption. Revision 1. Review Date September 2013. Page 1 of 6
Nyrstar Group Policy: Anti-Corruption Document No. (English) Revision 1 Review Date September 2013 Page 1 of 6 Contents 1 CONTEXT 3 2 SCOPE 3 3 REFERENCES AND RELATED DOCUMENTS 3 4 DEFINITIONS 3 5 BRIBERY
More informationAll questions relating to this Escalation Policy should be directed to Acacia s General Counsel.
1. Purpose Acacia Mining plc and its subsidiaries (collectively referred to as Acacia ) have adopted: a Code of Business Conduct and Ethics an Anti-bribery and Anti-Corruption Policy; an Anti-Fraud Policy;
More informationCEMEX Anti-Bribery/Anti-Corruption Global Policy
CEMEX Anti-Bribery/Anti-Corruption Global Policy Last updated: December 1, 2011 TABLE OF CONTENTS I. Policy... 1 II. International Anti-Bribery Laws... 1 A. Improper Payments... 2 B. Books and Records...
More informationCLARIPHY COMMUNICATIONS, INC. FCPA. Foreign Corrupt Practices Act. FIN-161- Compliance Policy Revision C August 1, 2015
CLARIPHY COMMUNICATIONS, INC. FCPA Foreign Corrupt Practices Act FIN-161- Compliance Policy Revision C August 1, 2015 7585 Irvine Center Drive, Suite 100 Irvine, CA 92618 Phone: 949.861.3074 Fax: 949.861.3087
More informationBBC. Anti-Bribery Policy. June 2011
BBC Anti-Bribery Policy June 2011 CONTENTS CLAUSE 1. Anti-Bribery Policy statement... 1 2. Who is covered by the policy?... 2 3. What is bribery?... 2 4. Gifts and hospitality... 3 5. Gifts and hospitality
More informationFCPA Compliance: An Investigator s Perspective. By Joseph Picarello
FCPA Compliance: An Investigator s Perspective By Joseph Picarello Agenda FCPA Overview Background Provisions What s prohibited? / What s permissible? Fines / Other Consequences UK Bribery Act Common Fraud
More informationNORTHERN POWER SYSTEMS. Code of Business Conduct and Ethics Chief Executive Officer s Message
Dear Colleague: NORTHERN POWER SYSTEMS Code of Business Conduct and Ethics Chief Executive Officer s Message March 3, 2015 Attached is our Code of Business Conduct and Ethics (the Code ). Our Code is a
More informationForeign Corrupt Practices Act ( FCPA )
Foreign Corrupt Practices Act ( FCPA ) OVERVIEW The Foreign Corrupt Practices Act ( FCPA ) was passed in 1977 in an effort to address concerns over the integrity of U.S. markets after hundreds of U.S.
More informationForeign Corrupt Practices Act Compliance
Document ID: LGL-D010 Rev 0 February 11, 2010 Page 1 of 6 Applies to: Aerojet Document Owners: Vice President, General Counsel and Executive Director, Contracts, Ethics & Compliance Purpose Background
More informationMICROSEMI CORPORATION FOREIGN CORRUPT PRACTICES ACT CORPORATE LEGAL MANUAL 1. POLICY 2. PURPOSE 3. SCOPE 4. PROVISIONS
1. POLICY Compliance with Foreign Corrupt Practices Act ( FCPA ) is required by law and also coincides with our culture of conducting business in an ethical manner. Everyone at Microsemi, including the
More informationRegulation for Compliance with Anti-Corruption Acts
Regulation for Compliance with Anti-Corruption Acts 2014. 2. 24. Samsung Techwin Co., Ltd. Table of Contents Chapter 1 Article 1 Article 2 Article 3 General Rules Purpose Applicability Definition Chapter
More informationGlobus Medical, Inc. Code of Ethics
Globus Medical, Inc. Code of Ethics 1. Introduction In performing their duties for Globus Medical, Inc. ( Globus ), each employee shall maintain the highest standards of honest and ethical conduct in all
More informationBARRICK GOLD CORPORATION
BARRICK GOLD CORPORATION Code of Business Conduct and Ethics Introduction Barrick s success is built on a foundation of personal and professional integrity and commitment to excellence. As a company and
More informationPark-Ohio Holdings Corp. Foreign Corrupt Practices Act Policy
Park-Ohio Holdings Corp. Foreign Corrupt Practices Act Policy I. Policy Park-Ohio Holdings Corp. ( Park Holdings or the Company ) is committed to conducting all operations and activities, including those
More informationFOREIGN CORRUPT PRACTICES ACT POLICY
FOREIGN CORRUPT PRACTICES ACT POLICY Purpose The purpose of this Policy is to ensure compliance from SWOP's employees and representatives with the US Foreign Corrupt Practices Act ("FCPA"). The Lay Person's
More informationhttp://appserver.lhsc.on.ca/policy/search_res.php?polid=gen041&live=1
Page 1 of 5 Policy Administration Console Policy: Standards for Business Conduct Policy Owner: VP Finance & CFO SLT Sponsor: VP Finance & CFO Approval By: Senior Leadership Team Date: 2008-06-25 Effective
More informationKeeping our Focus: Compliance Summary for Customers and Health Care Professionals. Understanding the Olympus Health Care Compliance Code of Conduct
Keeping our Focus: Compliance Summary for Customers and Health Care Professionals Understanding the Olympus Health Care Compliance Code of Conduct Introduction Olympus Corporation of the Americas ( Olympus
More informationCODE OF BUSINESS CONDUCT
CODE OF BUSINESS CONDUCT POLICY OBJECTIVES 1. This policy constitutes the Code of Business Conduct of companies of the Volga Gas Group (hereinafter called Group companies ). The Code applies to all employees
More informationFOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY
PURPOSE POLICY FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY This Policy ensures that China Xiniya Fashion Limited ( Xiniya ) complies with the Foreign Corrupt Practices Act 1977 ( FCPA ). Penalties
More informationBFB-G-42: Gifts Presented to Non- Employees on Behalf of the University
BFB-G-42: Gifts Presented to Non- Employees on Behalf of the University Responsible Officer: AVP - Systemwide Controller Responsible Office: FA - Financial Accounting Issuance Date: 10/17/2011 Effective
More informationForeign Corrupt Practices Act (FCPA) And Company Law
FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY The Company will conduct every business transaction (including without limitation, operations, negotiations, and marketing) with integrity and will comply
More informationANTI-CORRUPTION COMPLIANCE GUIDELINES
ANTI-CORRUPTION COMPLIANCE GUIDELINES INTRODUCTION These guidelines establish procedures for handling, and should help you identify anti-corruption concerns. If you are ever uncertain or feel uneasy about
More informationCalifornia Mutual Insurance Company Code of Business Conduct and Ethics
California Mutual Insurance Company Code of Business Conduct and Ethics This Code of Business Conduct and Ethics (the Code ) applies to all officers, employees, and directors of California Mutual Insurance
More informationCODE OF ETHICS POLICY
CODE OF ETHICS POLICY The YMCA's reputation is dependent upon the good judgment, ethical standards and personal integrity of every individual in the YMCA. As the YMCA continues to grow, it is of paramount
More informationNEW SENIOR INVESTMENT GROUP INC. CODE OF BUSINESS CONDUCT AND ETHICS October 16, 2014
NEW SENIOR INVESTMENT GROUP INC. CODE OF BUSINESS CONDUCT AND ETHICS October 16, 2014 The following sets forth New Senior Investment Group Inc. s Code of Business Conduct and Ethics (the Code ), which
More informationcompany policy number 0001 LEGAL AND ETHICAL CONDUCT
company policy number 0001 LEGAL AND ETHICAL CONDUCT eff. date replaces page 28 Mar. 2011 14 Feb. 2006 1 of 10 PURPOSE CPI has adopted this Code of Legal and Ethical Conduct ( Code ) to promote: honest
More informationCHAPTER 51. BE IT ENACTED by the Senate and General Assembly of the State of New Jersey:
CHAPTER 51 AN ACT concerning campaign contributions by certain business entities seeking or holding State contracts, supplementing P.L.1973, c.83 (C.19:44A-1 et seq.), amending P.L.2004, c.19, and repealing
More informationCODE OF BUSINESS CONDUCT AND ETHICS
CODE OF BUSINESS CONDUCT AND ETHICS Introduction This (the Code ) applies to Oceaneering International, Inc. and its subsidiaries and other affiliated companies (together referred to as our Company, us
More informationCode of Conduct of adidas AG Herzogenaurach
Code of Conduct of adidas AG Herzogenaurach Date of issue: October 27, 2006 Table of Content 1. Basic Rules of Conduct 3 1.1 Executive s duties 3 1.2 Basic Rules and Common Sense 4 2. Treatment of Business
More informationDole Food Company, Inc. and its Consolidated Subsidiaries
Dole Food Company, Inc. and its Consolidated Subsidiaries COMPLIANCE MANUAL FOREIGN CORRUPT PRACTICES ACT UNITED KINGDOM S BRIBERY ACT June 6, 2012-1 - 1. INTRODUCTION This Manual provides guidance for
More information