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BLUD » Topics » Improper Payments

This excerpt taken from the BLUD 8-K filed Apr 30, 2007.

Improper Payments

It is a violation of this Code of Conduct to make or offer to make any improper payment to an employee or official of any company, government or entity of any kind regardless of the benefit or potential benefit to the Company.  “Improper payments” include direct or indirect bribes, kickbacks or other payments for the purpose of acquiring and/or retaining business.

The form of the improper payment is irrelevant, and giving anything of value is expressly prohibited — cash, lavish gifts, excessive entertainment, vacation trips, “educational” trips without a sufficient educational component, personal loans and special favors.

Using third parties to facilitate improper payments is strictly prohibited, and the employee will be considered in violation of this Code as if the improper payment had been made directly.  Because such improper payments are sometimes routed through consultants and other service providers,

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