2022 Code of Ethics | Page 45

The Foreign Corrupt Practices Act ( FCPA ) prohibits payments , offers , or promises to give money , gifts or anything of value to foreign officials , political parties , or candidates for foreign political office in order to obtain , keep , or direct business to any person or company .
Examples of situations that may constitute improper payments to government officials include giving gifts of more than minimal value , providing entertainment , sponsoring government travel , or paying tips or other fees not required by law .
Indirect payments of this nature made through an intermediary are also illegal . BBNC must comply with the FCPA as well as anti-corruption laws in all jurisdictions where it conducts business . The following activities are prohibited :
Maintaining secret or unrecorded funds or assets ;
Falsifying records ;
Providing misleading or incomplete financial information to an auditor .
Your Responsibilities
Comply with the law and the highest ethical standards of the United States and the foreign country in which BBNC is doing business .
Do NOT make any payment , regardless of amount , to foreign government officials or personnel .
Do NOT use BBNC assets for any unlawful or improper use .
Do NOT create or maintain a secret or unrecorded fund or asset for any purpose .
The U . S . Government has established a “ Zero-Tolerance ” Policy on human ‘ trafficking in persons ’ ( TIP ) which addresses all forms of compelled services as described in the Trafficking Victims Protection Act ( TVPA ) including but not limited to :
Forced Labor Sex Trafficking Bonded Labor
Debt Bondage Among Migrant Laborers
Involuntary Domestic Servitude Forced Child Labor Child Soldiers Child Sex Trafficking
BBNC will take all necessary steps to remain in compliance with this law . TIP will not be facilitated in any way by or through BBNC ’ s activities , employees , or subcontractors . Employees are required to report violations , including violations by subcontractors . In compliance with FAR ( Federal Acquisition Regulation ) 52.222-50 , BBNC will cooperate with all federal agencies in the event of a TIP investigation pertaining to BBNC .
If you have a question about human trafficking , contact the BBNC Compliance Department .
42 BBNC Code of Ethics | Ethics Hotline : 1.866.513.7078 | August 5 , 2022 | info . bbnc . net