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FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY I. Purpose The purpose of this Foreign Corrupt Practices Compliance Policy (the CPA Policy “) is to help ensure compliance by WORLD PAC, Inc. and
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How to fill out the Foreign Corrupt Practices Act:

01
Understand the requirements: Familiarize yourself with the provisions of the Foreign Corrupt Practices Act (FCPA). Study the different sections, such as the anti-bribery provisions and accounting requirements, to have a clear understanding of what is expected.
02
Conduct a risk assessment: Evaluate your company's operations and identify potential risks related to corrupt practices. Consider factors like the countries where you conduct business, the involvement of third-party agents or intermediaries, and the level of interaction with government officials.
03
Establish internal controls: Implement comprehensive internal controls and compliance programs to prevent and detect any violations of the FCPA. This includes developing policies, procedures, and guidelines that are aligned with the Act's requirements and educating your employees on their responsibilities.
04
Designate a compliance officer: Appoint a compliance officer or team responsible for overseeing FCPA-related compliance activities within your organization. This individual or team should be well-versed in the Act's provisions and be able to effectively monitor and enforce compliance measures.
05
Conduct regular training: Provide FCPA-specific training to all relevant employees, including management, sales teams, and those in high-risk positions. The training should cover topics such as identifying red flags, reporting procedures, and ethical decision-making.
06
Implement due diligence procedures: Establish robust due diligence procedures for vetting third-party agents, consultants, and other business partners. Ensure that they are aware of and in compliance with the FCPA. Regularly review these relationships to mitigate any potential risks.
07
Maintain accurate and transparent records: Maintain accurate and transparent books, records, and accounts that properly reflect your company's transactions. Ensure that financial records are easily accessible and subject to regular audits to prevent any potential violations.
08
Promptly investigate and report violations: Establish an internal reporting system where employees can report any suspected FCPA violations anonymously and without fear of retaliation. Encourage a culture of integrity and accountability, and promptly investigate and address any reported issues.

Who needs the Foreign Corrupt Practices Act?

The Foreign Corrupt Practices Act applies to:

01
U.S. Companies: Any company incorporated in the United States, regardless of where it conducts business, is subject to the FCPA. This includes both domestic operations and overseas subsidiaries.
02
Foreign Companies: Non-U.S. companies that have securities listed on U.S. stock exchanges or conduct any business in the United States fall within the jurisdiction of the FCPA.
03
Individuals: The FCPA also applies to individuals associated with U.S. companies, such as officers, directors, employees, agents, and shareholders, who engage in corrupt practices related to foreign business transactions.
In summary, anyone who conducts business operations in the United States or is associated with a U.S. company must comply with the provisions of the Foreign Corrupt Practices Act.
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