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Areas of potential violations

Areas within the collateral recovery industry where Recovery Agency owners, or employees
may violate Anti-Corruption and Anti-Bribery laws include but are not limited to the
following:

1. Clients
2. Prospective/potential clients
3. Vendors of recovery agencies, clients or prospective/potential clients
4. Customers of a lender

Questions or How to Raise a Concern

If you ever have an occasion to question whether something may be considered a bribe or a
corrupt act you need to report the violation. If you’re unsure who to report it to, it is suggested
at a minimum you follow your chain of command. Report it immediately to one of the
following:

• Your manager
• The owner
• The board of director

Compliance

For Recovery Agency owner’s it is HIGHLY recommended that there is ongoing employee
training and documentation of training specific to Anti-Corruption/Anti-Bribery.

Below is an example of a company policy for each new hire to sign. This signed statement
acknowledges your company policy with respect to Anti-Corruption/Anti-Bribery. It should
be saved within the employee’s file and also part of your compliance documents.

(Name of Recovery Agency) strictly prohibits employees from offering payments of
gifts, money, or other items of value, either directly or indirectly, for any purpose, to
any entity or individual including but not limited to the following:

1. Clients and/or prospective clients.
2. Vendors and/or potential vendors of (name of Recovery Agency), clients or potential
clients.

Prohibited items of value regarding such offers include but are not limited to:

1. Meals, travel expenses, entertainment, gifts or other expenses of hospitability.
2. Charitable contributions for the purpose of obtaining or retaining business from
any individual or entity listed above.
3. Sponsorships (for individuals, teams, products, etc.), to any entity listed above.
4. Charitable contributions to a political party(s), or campaign official for the purpose
of obtaining or retaining business from any entity listed above.

Any employee of (name of Recovery Agency) found in violation of this company policy
shall be subject to immediate termination of employment.

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