The US Foreign Corrupt Practices Act (“FCPA”) prohibits all US companies and persons from offering, paying or authorizing the payment of anything of value, directly or indirectly, to any foreign official to obtain or retain business or obtain any other business advantage.
IntelePeer is committed to conducting its business in an ethical and honest manner and acting professionally, fairly, and with integrity in all business dealings and relationships. IntelePeer will constantly uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate.
This policy applies to all persons working for IntelePeer in any capacity, including employees, directors, officers, board member, consultants, analysts, contractors, interns, agents, sponsors, or any other person associated with IntelePeer.
Employees shall not:
- receive, pay, offer to pay, promise to pay, or authorize a payment;
- of money, gift or any item of value;
- to:(i) any foreign official, foreign political party or party official or any candidate for foreign political office, in order to influence any act or decision of that official; or(ii) any person, while knowing that all or a portion of that money or item of value will be offered, given, promised directly or indirectly to a foreign official;
- to induce that foreign official to use their position in order that the company can secure another improper advantage to obtain or retain business.
GIFTS, HOSPITALITY AND EXPENSES
IntelePeer prohibits offering improper gifts, entertainment, and hospitality, such as the payment of hotel, transportation, meal and entertainment expenses, directly or indirectly to any government official. This policy does not prohibit giving or accepting normal gestures of hospitality, so long as it is reasonable, appropriate, modest, and for legitimate purposes such as building relationships or marketing our products and services.
FACILITATION PAYMENTS AND KICKBACKS
IntelePeer prohibits making or accepting facilitation payments or kickbacks of any kind. Facilitation payments are payments made to expedite or ensure action by an official. Kickbacks are payments made in return for a business favor or advantage.
IntelePeer encourages and employees make contributions to charities, social projects and funds, if they are ethical and in compliance with this policy and applicable laws.
DUE DILIGENCE REQUIREMENTS FOR THIRD PARTIES
Third parties can put IntelePeer at risk if they do not follow ethical business practices. Therefore, risk appropriate due diligence and on-going monitoring of Third Parties and the implementation of appropriate steps to address any identified risks, to ensure compliance with applicable anti-corruption laws is required.
DUTY TO REPORT
Employees must immediately report any suspected or actual violations of this policy or the FCPA to his/her Manager, Human Resources or any other Manager. If you are unsure whether a certain action or behavior constitutes bribery or corruption, you should report the matter.
ASSURANCE OF NON-RETALITION
IntelePeer encourages openness and will support anyone who raises genuine concerns in good faith under this policy.
Under no circumstances shall refusing to take part in corruption, raising concerns or reporting another’s potential act of bribery or corruption serve as a basis for retaliation against an employee, solongas that employee acted in good faith.
If you believe that you have suffered any detrimental treatment as a result of refusing to take part in corruption, or because of reporting a concern under this policy in good faith, you should inform your Manager or Human Resources immediately.
TRAINING AND COMMUNICATION
IntelePeer will provide training on this policy to all for all directors, officers, relevant employees, and where appropriate, agents and business partners.
IntelePeer’s anti-bribery and corruption policy and zero-tolerance attitude will be clearly communicated to all suppliers, contractors, business partners, and any third parties at the outset of business relations, and as appropriate thereafter.
Significant penalties for both IntelePeer and employees could result from violations of the FCPA. Breach of any of the terms and conditions of this policy may result in disciplinary action, which may include penalties up to and including termination of employment.