Prohibition of Improper Payments
The Company expects all employees to use only legitimate practices in commercial operations and in promoting the Company position on issues before governmental authorities. As stated below, "kickbacks" or “bribes" intended to induce or reward favorable buying decisions and governmental actions are unacceptable and prohibited. No employee of the Company or any Controlled Affiliate acting on the Company's behalf shall, in violation of any applicable law, offer or make directly or indirectly through any other person or firm, any payment of anything of value (in the form of compensation, gift, contribution or otherwise) to:
1. Any person or firm employed by or acting for or on behalf of any customer, whether private or Governmental, for the purpose of inducing or rewarding any favorable action by the customer in any Commercial transaction; or any governmental entity, for the purpose of inducing or rewarding action (or withholding of action) by a governmental entity in any governmental matter;
2. Any governmental official, political party or official of such party, or any candidate for political Office, for the purpose of inducing or rewarding favorable action (or withholding of action) or the Exercise of influence by such official, party or candidate in any commercial transaction or in any Governmental matter.
In utilizing consultants, agents, sales representatives or others, the Company will employ only reputable, qualified individuals or firms under compensation arrangements which are reasonable in relation to the services performed. The Executive Department will issue from time to time criteria and procedures to be utilized in international transactions with respect to the selection and compensation of sales representatives. Consultants, agents or representatives retained in relation to the provision of goods or services to the government must agree to comply with all laws, regulations and Company policies governing employee conduct.