BizMod LLC prohibits bribery of any kind, including commercial bribery, and has adopted a zero tolerance policy for bribery in all its operations and activities. This means BizMod LLC and Third Parties that provide services to and/or act on behalf of BizMod LLC may not engage in any form of bribery, including offering, soliciting or accepting anything of value, directly or indirectly, that is given with the intent to obtain or retain business or an improper advantage or to secure services. There is no exception for small amounts.

If Third Parties interact with government officials (including officials of international organizations and political parties, as well as employees of state-owned companies) in the course of providing services to and/or acting on behalf of BizMod LLC, employees must be especially cautious. Third Party employees may not offer or promise anything of value to influence the actions or decisions of, or to obtain any improper advantage with, government employees or the government bodies they may influence.

Expediting payments (also known as “facilitating” or “grease” payments) are payments made to speed up or secure the performance of a routine government action, such as visa processing or customs clearance. These payments are considered illegal bribes in many jurisdictions, including those with laws applicable to BizMod LLC. Third Parties may not make any expediting payments to government employees on behalf of or in connection with services performed for BizMod LLC, no matter where the Third Party is conducting business. This is true regardless of local customs in the locations where the Third Party conduct business.

In connection with their engagement with BizMod LLC, Third Parties and their employees should be cautious when giving gifts or entertainment to, or accepting gifts or entertainment from, anyone who does or seeks to conduct business with the Third Party. Giving or accepting gifts and entertainment may appear to influence the recipient’s ability to make objective business decisions. Third Party employees may provide and accept meals, entertainment, token gifts or favors that have a valid business purpose, do not have significant value and do not create a real or apparent sense of obligation.

In some countries, it is traditional to present gifts to business associates to demonstrate courtesy or appreciation. Third Parties and their employees may never offer gifts to government officials with whom they are conducting or seeking to conduct business on behalf of BizMod LLC or before whom they are representing BizMod LLC. As appropriate, and consistent with these Shared Values, Third Parties may give gifts to non-government officials in locations where doing so is customary, widely accepted and consistent with local laws, rules and regulations and permitted by the Third Party’s policies. Such gifts must be of reasonable value and properly reported.

Reporting accurate, complete and understandable information about the Third Party’s business, earnings and financial condition is one of an employee’s most important duties. Third Parties should ensure that their accounting and financial records meet the highest standards of accuracy and completeness. Third Party employees must never make any false or artificial entries in the Third Party’s books and records related to their engagement with BizMod LLC.

Third Party employees should record financial transactions accurately, completely, fairly, and in a timely and understandable manner. Third Parties must ensure that the data they provide to BizMod LLC for the preparation of financial statements, regulatory reports and publicly-filed documents complies with all applicable accepted accounting principles and the Third Party’s internal control procedures.

If a Third Party employee has reason to believe that any of the Third Party’s books or records related to BizMod LLC are being maintained in a fraudulent, inaccurate or incomplete manner, or feels pressured to prepare, alter, conceal or destroy documents, he or she should report these concerns immediately to BizMod LLC.