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ABII » Topics » Facilitating Payments to Low-Level Non-U.S. Governmental Employees and Officials for Non-Discretionary Action

This excerpt taken from the ABII 10-K filed Mar 31, 2008.

Facilitating Payments to Low-Level Non-U.S. Governmental Employees and Officials for Non-Discretionary Action

As noted above, the Company is committed to complying with the laws of the countries where it operates. In some countries, a very limited category of small payments to facilitate or expedite routine non-discretionary governmental actions may be permitted as exceptions to anti-bribery laws, including the U.S. Foreign Corrupt Practices Act. The requirements pertaining to such payments are complex. Company employees engaged in international business activities should be familiar with the rules regarding this type of payment and must obtain prior approval of the Chief Compliance Officer before making any such payment.

These “facilitating payments” to non-U.S. governmental officials are distinguished from payments made to influence a discretionary decision or to cause violation of, or an act in conflict with, the interests of an individual’s employer, which are strictly prohibited.

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