Medical WorldTech adheres strictly to the U.S. Foreign Corrupt Practices Act (“FCPA”) to ensure ethical business dealings with all partners.
International Business Conduct The Company has an international presence and thus, certain Associates or other affiliates of the company may find it necessary to interact with foreign governments or officials in the furtherance of the Company’s business activities. In any dealings with foreign officials, candidates, or political parties, the Company and its Associates, consultants, agents, subsidiaries, distributors, resellers, and representatives, must comply with the following policy. Generally, the Company’s policies, the U.S. Foreign Corrupt Practices Act (“FCPA”), and applicable domestic and foreign laws prohibit payments to, and business relationships with, government officials (“government officials” may include employees of entities that are stateowned, in whole or part, public international organizations and political parties or political candidates) that could be construed as bribes or attempts to influence government behavior. Associates may not give, offer, promise, or authorize direct or indirect payments to foreign officials for the purpose of obtaining or retaining business for the Company. Payments include money, gifts, or anything of value, and need not actually be delivered, but merely have been intended for a corrupt purpose, to violate the FCPA. It is therefore illegal and against the Company policy for any Associate or other Company representative to offer or give anything of value that is intended to:
- influence any act or decision of a foreign official in his or her official capacity; • induce the official violate a lawful duty of his position or to use his influence improperly; or • obtain an improper advantage for the Company. The Company and individuals may face significant civil and criminal punishment in both the United States and in other countries, including imprisonment, for violating the FCPA and similar, applicable anti-bribery laws. Acknowledging that in certain foreign localities, payments to local government officials may be customary to expedite processes such as the granting of a business license or similarly routine governmental action, the FCPA contains a narrow exception for such payments. In every case, prior to making, promising, or offering any such payment, any Associate or affiliate of the Company must consult with the CFO should uncertainties arise. Furthermore, if it is determined that a payment meets this narrow exception, it must be recorded accurately by the accounting department, as it is an independent violation of the FCPA to mischaracterize any such payment in the financial records. Both the consultation with the CFO and the accounting treatment of the payment must be documented in writing.