Page 117 - Employee Handbook

internal and accounting controls to assure that transactions are executed solely
in accordance with management directives, and are properly recorded, and
regularly and properly audit these records so that financial statements can be
prepared in accordance with proper accounting standards.
Penalties for Violation
FCPA violations can subject individuals to fines of the greater of US$250,000 or
twice the gross gain or loss from the offense, and mandatory, substantial prison
terms.
The Company may be fined up to US$2 million or twice the gross gain or
loss from the offense. For Criminal Violations, Federal Sentencing Guidelines
add incremental fines including US $250,000 for individuals and US$500,000
for corporations. Furthermore, the U.S. Government can bar the Company
from doing business with the US Federal Government (debarment), or use
its regulatory power with such agencies as the US Securities and Exchange
Commission or the US Food and Drug Administration, to impose sanctions.

Some Guidelines
The United States Government has issued various guidelines and advisory
opinions which indicate that certain types of business activities may be
acceptable under certain circumstances:
Occasional business courtesies (gifts) and reimbursements for meals provided
to foreign officials are generally permissible if:
a) legal in the country (check this in advance. Other countries may have lower
limits or may prohibit courtesies or meals entirely), and
b) modest in the context of the country. Normally the following guidelines
should be observed, unless a variation is specifically approved by your
Manager.
Gifts
This is only permissible if it bears the company logo, and is less than US$100 in
value. Gifts can include a one-time meal, so long as it is less than the following
(per person in U.S. dollars):
Breakfast: < or = $50 per person
Lunch: < or = $75 per person
Dinner: < or = $100 per person
Repeated courtesies, gifts or reimbursements may raise questions even if they
comply strictly with these guidelines. Normally, meals and gifts should not also
be provided to a spouse, guest, or family member.

117 Employee Handbook