Worldwide Anti-Corruption Policy



The laws of most countries make the payment or offer of payment or even receipt of a bribe, kickback or other corrupt payment a crime, subjecting both GFS and individual employees to fines and/or imprisonment. These anti-corruption laws, including the U.S. Foreign Corrupt Practices Act (FCPA), make it a crime to pay, offer, or give anything of value to foreign governmental officials, a foreign political party (or official thereof) or candidate for foreign office, for the purpose of influencing the acts or decisions of those officials, parties or candidates. This is true even if such payments are common within the country in question.

The purpose of this Policy is to ensure compliance by all employees, officers and directors of GFS, and its subsidiaries and affiliates, with the FCPA and related anti-corruption laws of other countries in which the Company does or intends to do business. This Policy covers the following:

 Bribes, Kickbacks or Other Corrupt Payments
 Facilitation Payments
 Relationships with Third Parties


This Policy applies to all employees, officers and directors of GFS and its subsidiaries and affiliates worldwide. This policy should be read in conjunction with GFS’S Code of Ethics and Worldwide Gift and Entertainment Policy.


Bribes, Kickbacks or Other Corrupt Payments

It is the policy of GFS that, in doing business anywhere in the world, GFS, all affiliates, employees, officers and directors of GFS or any of its affiliates, and all persons that act as a representative, agent, or advisor to GFS or any of its affiliates, must comply fully with applicable anti-corruption laws, especially the FCPA. GFS employees are prohibited from directly or indirectly offering, giving, soliciting or receiving any form of bribe, kickback or other corrupt payment, or anything of value, to or from any person or organization, including government agencies, individual government officials, private companies and employees of those private companies under any circumstances.

This prohibition applies:

 World-wide, without exception.
 Without regard to regional customs, local practices or competitive conditions.
 To the indirect payment of any such bribe, kickback or other corrupt payment that may be carried out through third parties, such as representatives, consultants, brokers, contractors, suppliers, joint ventures or affiliates, or any other intermediary or agent acting on behalf of GFS.

No employee will be penalized for any delay or loss of business resulting from his or her refusal to pay a bribe.

Third Parties

This policy prohibits corrupt offers, promises and payments made through partners, intermediary agents, joint ventures, or third parties. Therefore, it is important to conduct due diligence on such partners or agents, and not disregard or ignore facts which indicate a probability that a corrupt payment may occur. The purpose of due diligence is to ensure, to the extent possible, that GFS retains only reputable and honest agents, representatives and partners. In addition, contracts with agents or third-party representatives and joint venture partners should, to the extent possible, include provisions to mitigate against the risk of potential illicit payments.

Facilitation Payments

While U.S. law allows for the payment of facilitation payments (provided they are properly reported in the company’s financial records), such payments are illegal under the local laws of most, if not all, non-U.S. countries. Facilitation payments are payments of small amounts made to secure or expedite the performance of routine non-discretionary government action by non-U.S. clerical level government officials. Examples of facilitation payments may be obtaining routine permits to do business, processing visas and work orders, obtaining mail or telephone services, or expediting shipments through customs (assuming all legal requirements for obtaining these have been satisfied).

GFS prohibits the payment of facilitation payments except under the following two conditions and only with prior approval by GFS’s Law Department (or, if prior approval is not reasonably possible given the circumstances, as soon as possible following such payment):

 The failure to make the payment would create a risk to an employee’s (or his or her traveling companions’) personal health or safety or physical or mental well-being.
 The failure to make the payment would result in imminent and substantial economic loss or cost to GFS as a result of a government official’s failure to perform a non-discretionary service GFS is otherwise legally entitled to obtain, such as where the opening of a production facility is delayed because of a refusal to turn on basic water, electric or phone service the operation is otherwise entitled to have.