Page 115 - Employee Handbook

and familiar with the laws which govern the countries in which they conduct
business.
No Employee may break or seek to evade applicable laws or regulations of
any country in, though, or with which the Company seeks to do business. All
Employees and Associated Persons must comply with all other laws regulating
payments associated with reimbursements by governmental programs.
The fact that an illegal act may be a “customary business practice” in a
particular country is not sufficient justification for violation of this provision.
All requests for any payment prohibited by the FCPA or other laws must be
expressly rejected and reported to the Compliance Officer or COO of mdgroup.
Any violation of this policy by a mdgroup Employee may subject that individual
to disciplinary action by the Company up to and including termination, as well
as potential criminal and/or civil liability.
It is each Employee’s personal responsibility to bring violations or suspected
violations of this policy to the Compliance Officer or COO. Please immediately
report any conduct you suspect to be a violation of the Policy to the Compliance
Officer or COO.
Employees reporting matters of concern in good faith will not be subject to
retaliation.
What the FCPA Provides
The FCPA is a broad anti-bribery law that prohibits most payments made by
United States companies and individuals and their foreign subsidiaries (a
“Company”) to a non-US official (a “foreign official”) to induce that person to
use influence to affect a government act or decision to assist the Company to
obtain or retain business or other prohibited purposes. The following summary
of some of the provisions of the FCPA is intended to provide general familiarity
with the FCPA, but should not be considered to be legal advice. Consult with
the Compliance Officer or COO if you
have specific questions or concerns.
Prohibited payments do not just
mean cash. A prohibited payment
may also include, among other things:
a) gifts or lavish entertainment (for
more detail see below),
b) reimbursement of other personal
expenses (education, travel, etc.),
c) loans, etc.

115 Employee Handbook