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2. FOREIGN GOVERNMENT ACTIVITY: Business conduct in foreign countries sometimes differs from that in the U.S., both in terms of common practice and legality. The simple overriding consideration is that if any unethical or illegal activity is necessary to obtain or retain any business, Gulfstream will not pursue or seek to retain that business. Gulfstream will observe the laws of foreign countries in which it operates concerning payment of agents' fees and commissions, provided these laws are not in conflict with U.S. law. Employees and agents of Gulfstream are not to engage in activities designed to circumvent foreign laws concerning retaining or paying sales representatives and consultants. Individuals who have international responsibilities must become familiar with the Foreign Corrupt Practices Act, a US law (the “FCPA”), together with international anti bribery legislation enacted in accordance with Organization for Economic Cooperation and Development “Convention on Combating Bribery of Foreign Public Officials in International Business Transactions” (the “OEDC Convention”), which imposes criminal and civil sanctions on Gulfstream (and its employees who violate such laws) if it makes direct or indirect payments to any foreign government official to influence his/her actions or decisions or to induce him/her to use his/her influence to help Gulfstream. Anyone who willfully violates the FCPA or laws in various foreign countries adopted pursuant to the OEDC Convention, may be fined and/or imprisoned in such countries. A copy of the FCPA or the OEDC Convention and help in understanding them are available in the Gulfstream Legal department, which is the FCPA Compliance Office for Gulfstream. Consistent with the FCPA and the OEDC Convention, it is strictly prohibited for any Gulfstream employee to offer, pay, promise to pay, or authorize the payment of money or anything of value to any foreign government official for the purpose influencing any act or decision of such government official or securing any improper advantage in order to assist in obtaining or retaining business. A foreign official is any individual, regardless of rank or position, who is: 中国公务机网 www.gongwuji.com 公务机翻译 www.aviation.cn 本文链接地址：湾流宇航公司公司政策手册 Gulfstream Aerospace Corporation Corporate Policy Manual(8) |
