Federal Consulting Services (the “Company”) is committed to conducting business ethically, with integrity, and in compliance with all applicable anti-corruption laws, including the U.S. Foreign Corrupt Practices Act (FCPA). This Policy applies to all Company officers, employees, and third parties acting on the Company’s behalf.
Prohibited Payments Company personnel are prohibited from directly or indirectly offering, promising, authorizing or providing anything of value to any customer, government official, or other third party in order to secure an improper business advantage. “Anything of value” should be broadly interpreted and includes cash, gifts, entertainment, travel expenses, favors, services, loans and offers of employment.
Gifts, Travel & Entertainment Reasonable and bona fide gifts, travel and entertainment may be provided to customers and government officials only if:
- The expenses are directly related to the promotion or demonstration of Company products/services or performance of a contract
- The expenses are modest in value, infrequent, and permissible under local laws and customs
- The expenses are properly recorded in the Company’s books and records
- Written approval is obtained in advance from the Compliance Department for gifts over $100 in value or travel/entertainment over $250 in value
Any gifts, travel or entertainment provided to U.S. or foreign government officials requires prior approval from the Compliance Department regardless of value. Cash gifts to customers or government officials are never permitted.
Commissions, Discounts & Fees Any commissions, discounts, fees or other payments made to customers, agents, distributors or other third parties must:
- Be reasonable in value and consistent with industry practice
- Reflect bona fide services rendered or products provided
- Be properly documented and accounted for in the Company’s books and records
- Not be made in cash or to/from unrelated third parties
Due Diligence & Monitoring The Company will conduct risk-based due diligence on third parties engaged to act on its behalf, including sales agents, distributors, consultants and vendors. Due diligence includes evaluating the third party’s qualifications, background and reputation. Third parties must agree in writing to abide by the Company’s anti-corruption policy.
The activities and expenses of third parties will be properly monitored and any red flags or suspicious activities must be reported to the Compliance Department for review and appropriate action.
Books & Records All transactions must be accurately recorded in the Company’s books and records. There must be no “off-books” accounts or false/misleading entries made for any reason.
Reporting & Investigations Any suspected violations of this policy must be promptly reported to a supervisor, Human Resources, or the Compliance Department. The Company prohibits retaliation against anyone who makes a good faith report of suspected misconduct.
All reports will be investigated and disciplinary action taken against violators, up to and including termination. The Company will cooperate with law enforcement authorities regarding any violations of law.
Training & Certification Company personnel will receive periodic training on this anti-corruption policy. All personnel must certify in writing on an annual basis that they have read, understand and agree to abide by this policy.
June 4, 2024