BBNC Code of Ethics Code of Ethics_Light_final_joomag 2 | Page 34

FOREIGN CORRUPT PRACTICES ACT
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 they
conduct business. The following
activities are prohibited:
Maintaining secret or unrecorded
funds or assets;
Falsifying records;
Providing misleading or
incomplete financial information
to an auditor.
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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.