Page 118 - Employee Handbook

Certain other payments may be permissible, but should be approved in advance
by the COO and Compliance Officer.
Hosting Foreign Officials
Reasonable and bona fide costs of travel and lodging may be permissible if the
costs are directly related to
a) the promotion, demonstration or explanation of products or services; or
b) the execution or performance of a contract with a foreign government or
agency. “Side Trips” focused on entertainment are prohibited since they are
not “directly related” to the demonstration or explanation or products or
services or the execution or performance of a contract.
Reimbursement for international travel or per diem payments is rarely
acceptable. Consult the Compliance Officer or COO before authorising or
incurring such expenses.
Facilitating Payments
These so-called “grease payments” are payments to expedite or secure the
performance of routine government actions. Under the FCPA, these payments
may be permissible under certain circumstances. Such actions include obtaining
official documents; processing governmental papers, such as visas and work
orders; providing police protection, mail pickup and delivery; loading and
unloading cargo; and actions of a similar nature. Such payments may also
violate other laws, are discouraged, and must be carefully reviewed.
You must consult the Compliance Officer or COO before authorising or incurring
such expenses.

Employing Foreign Consultants, Agents
The employment of foreign consultants, etc, can result in inadvertent exposures
to US FCPA and other legal prohibitions. To minimise this risk, the following
guidelines should normally be followed:
a) You must use written agreements
which include the Company’s
standard FCPA compliance language,
and attach a summary of FCPA
requirements.
b) For consultants hired to help with
government-related business, review
the situation to avoid FCPA questions
and if unsure contact the Compliance
Officer or COO.

Employee Handbook 118