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IDEXX Global Anti-Bribery and Corruption Policy FAQs

Q: Why is anti-bribery and corruption compliance important?

A: The majority of countries in which IDEXX does business have enacted laws aimed at combating
bribery and other forms of corruption. These laws include the U.S. Foreign Corrupt Practices Act (the
“FCPA”), the UK Bribery Act of 2010 (the “UKBA”), as well as an ever growing patchwork of localized
anti-bribery and corruption laws. Under these laws, it is a crime to give, pay, or promise anything of
value in order to improperly influence an act or decision to obtain, retain and/or direct business or to
secure an improper advantage of any kind. Importantly, a number of these laws, including the FCPA and
the UKBA, may apply to corruption anywhere in the world.
The consequences of failing to comply with the FCPA, the UKBA or similar anti-bribery and corruption
laws are potentially severe. Violations by any IDEXX employee, officer, distributor, agent, business
partner or other affiliate may result in millions of dollars in fines against IDEXX and may subject the
violating individual to prosecution, criminal fines and imprisonment. In addition, actual or perceived
violations of anti-corruption laws can tarnish IDEXX’s reputation.
Q: Who does the IDEXX Anti-Bribery and Corruption Policy apply to?

A: All employees, agents and affiliates of IDEXX and its subsidiaries.

Q: Are IDEXX distributors considered “agents” of IDEXX?

A: Yes. It is important to remember that our agents, including our distributors, may not do something on
behalf of IDEXX that we are prohibited from doing ourselves. IDEXX and its employees may be held liable
for the conduct of its agents and other third party intermediaries (such as distributors).

Q: What is a bribe?

A: The giving, offering, promising or paying anything of value to anyone with the purpose or intent of
improperly obtaining or retaining business or otherwise securing an improper business advantage.

Q: The IDEXX Policy strictly prohibits “facilitation payments” – what are these?

A: A facilitation payment is sometimes referred to as a “grease” payment and means any unofficial
payment made to a public official (or other person) to secure or expedite the performance of a routine,
non-discretionary action required to be performed as a matter of course.
Examples include payments made to:
 Obtain an ordinary license or business permit.
 Process government papers such as visas.
 Provide police protection.
 Provide telephone, power or water service.
 Release conforming goods held in customs.
 Load or unload cargo.

Q: What is included in the term “anything of value”?

A: The term “anything of value” must be interpreted very broadly and includes, but is not limited to,
cash, cash equivalents (such as gift certificates, gift cards, vouchers or loans), gifts, travel, meals,

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entertainment, use of vehicles, accommodations or valuable favors, such as educational and
employment opportunities for friends and relatives.

Q: The Policy requires that IDEXX keep accurate books and records, what does this mean exactly?

A: IDEXX must accurately and transparently record and describe all financial transactions and
disposition of assets. The following transactions are prohibited:

 false, misleading or incomplete entries in IDEXX’s books, records and other business documents;

 undisclosed or unrecorded funds or accounts;

 circumventing or evading, or attempting to circumvent or evade, IDEXX’s internal accounting


controls; and

 payment on behalf of IDEXX approved or made without adequate supporting documentation or


approved or made with the intention or understanding that all or any part of the payment is to be
used for any purpose other than the specific purpose described by the documents supporting the
payment.

Q: If I have concerns that something is happening that may be a violation of this Policy, what should I
do?

A: If you discover or otherwise learn of any event, payment scheme, or other action which you believe
is (or may be) in violation of any part of this Policy or any “red flag,” immediately communicate up the
discovery to one of the following:
 Your manager.
 Your local Legal team contact.
 The Compliance team (compliance@idexx.com).
 Via any of the Business Conduct Hotline reporting channels described on the Compliance team’s
page on the Intradexx.
 The Chief Compliance Officer.
Your concerns will be investigated, and if necessary action will be taken. Remember, pursuant to IDEXX’s
Ethics Code, retaliation or harassment will not be tolerated in any instance where a concern was raised
in good faith. If on the other hand you fail to communicate a violation of this Policy, engage in the
violation of this Policy, or hinder an investigation into potential violations of this Policy, you are subject
to disciplinary action up to and including termination.

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