Code of Ethics and Business Conduct

Anti-Corruption and Anti-Bribery Policy

The Foreign Corrupt Practices Act (“FCPA”) makes it a criminal offense for a United States company or agents acting on its behalf to pay anything of value (cash, cash equivalents, goods and services, consulting agreements, speaker fees, research agreements, travel, hospitality, meals, favors, entertainment, donations, gifts, or anything that confers a personal benefit) as a bribe to a foreign governments or officials in order to benefit the business needs of the United States company.
It is the Company’s policy that all team members and business partners comply with the ethical standards and applicable legal requirements of the FCPA and of each foreign country in which business is conducted.

The FCPA’s anti-bribery provisions also make it illegal for United States companies or agents representing them to make contributions to foreign political parties or candidates with the intent to influence their actions. It is illegal in the United States under these provisions, regardless of whether the donation is legal in the country where it is made.

Additionally, the Foreign Extortion Prevention Act (“FEPA”) criminalizes the demand side of international corruption by amending domestic bribery statute 18 U.S.C. § 201 to make it unlawful for a foreign government official “to corruptly demand, seek, receive, accept, or agree to receive or accept, directly or indirectly, anything of value” from United States persons or companies in exchange for allowing them to do business abroad.

Any violation or suspected violation of the Code by team members or business partners may be reported directly to the Ethics Officer. Violations may also be reported anonymously via the Ethics Hotline at 833-964-0232 (New York and Miami) or 1-844-444-6383 (Bimini).