Page 114 - Employee Handbook

13. Foreign Corrupt Practices Act (FCPA) Policy

mdgroup is committed to the highest standards of ethical conduct and integrity
in its business activities and this policy confirms the Company’s position on
preventing and prohibiting Foreign Corruption and bribery, in accordance with
the FCPA rules and regulations.
The Company will not tolerate any form of bribery by, or of, its employees,
agents or consultants or any person or body acting on its’ behalf. Senior
management is committed to implementing effective measures to prevent,
monitor and eliminate any potential act of bribery.
Scope of this Policy
This policy applies to all employees and officers of mdgroup and to temporary
workers, Consultants, contractors, agents and subsidiaries acting for, or on
behalf of, mdgroup (“associated persons”). Every employee and associated
person acting for, or on behalf of, mdgroup is responsible for maintaining
the highest standards of business conduct. Any breach of this policy is likely
to constitute a serious disciplinary, contractual and criminal matter for the
individual concerned and may cause serious damage to the reputation and
standing of mdgroup.
It has been and continues to be the policy of mdgroup and its subsidiaries and
affiliates (“mdgroup” or “Company”) to conduct its business in full compliance
with the United States (US) Foreign Corrupt Practices Act (15 US Code §78dd-1;
the “FCPA”).
The basic objective of this law is to encourage the ethical business with
foreign governments and agencies. No Company officer, employee, or agent
(collectively “Employee” and ‘Associated Persons’) has authority to offer
payments to any foreign official to induce that official to affect any government
act or decision in a manner that will assist the Company to obtain or retain
business, or otherwise to violate the FCPA in any way.
Every Employee and Associated person is responsible for keeping books,
records, and accounts that accurately and fairly reflect all transactions and
disposition of Company assets.
Many nations and international organisations also have issued laws and
statutes which prohibit bribery of public officials and others in connection with
business activities. Like the FCPA, these laws can subject the Company, and the
individuals involved, to substantial civil and criminal penalties, including large
fines, substantial imprisonment, or worse. Some of these laws go further than
the FCPA and prohibit activities which may be permitted under US law.
All mdgroup Employees and Associated Persons must make themselves aware

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