FOREIGN CORRUPT PRACTICES ACT POLICY

(FCPA)

"NO bribe" policy both internally and externally.

MONDIAL will conduct its business in compliance with all applicable Laws and in accordance with ethical standards. Mondial prohibits all Directors, Employees, Legal Agents and Third Parties acting on behalf of the company from paying, offering, promising or authorizing any bribe, kickback or other similar unlawful payment of money or anything of value to any public official or government employee, political party or party official, candidate for public office or other individual, in any country.

MONDIAL requires its Directors, Employees, Legal Agents and Third Parties acting on behalf of the company to comply at all times with the U.S. Foreign Corrupt Practices Act ("FCPA") and other applicable anti-corruption laws.

MONDIAL prohibits companies and individuals from corruptly offering, promising, authorizing or giving anything of value to a Foreign Official for the purpose of influencing any act or decision of such Foreign Official in his or her official capacity or in violation of his or her lawful duties in order to secure any improper advantage in order to obtain or retain business or direct business to any person. Because many improper payments are made through intermediaries rather than employees of the company that desire the business or advantage, the FCPA also prohibits the offering or paying of anything of value to any person if it is known that all or part of the payment will be offered, given or promised to a Foreign Official for the improper purposes discussed above.

  • Any payment to a Foreign Official, including excessive entertainment, travel, gifts of significant value could be considered as a payment of something of value to obtain or retain business or unduly influence some behavior in favor of the company and therefore could be a violation of the FCPA or other applicable anti-corruption law. Accordingly, extravagant or frequent business courtesies are prohibited.
  • All transactions should be accurately, transparently, and timely recorded in the Company's books and records with sufficient detail and documentation to support the transactions in accordance with the MONDIAL's accounting procedures.
  • All Third Parties who may interact with Foreign Officials on behalf of the Company shall agree in writing to follow all applicable portions of this Policy.
  • The Director of Compliance shall be responsible for establishing the procedures necessary to implement this Policy.