Local and foreign laws. No officer, associate or representative may, directly or indirectly, break or seek to evade the laws or regulations of any country in, through or with which business is sought, regardless of customary business practice.
Bribery and facilitating payments. Bribes are not offered or provided, and all demands for bribes are expressly rejected. Facilitating payments are prohibited, except where urgent action is required concerning health or safety.
Kick-backs. No portion of contract payments may be returned or channelled to public officials or employees of other parties through subcontracts, purchase orders or consulting agreements.
Conflict of interest. Affiliates, employees and representatives shall avoid any relationship or activity that might impair, or appear to impair, their ability to render objective and appropriate business decisions.
Political contributions. No political contribution may be made in order to obtain an unlawful business advantage, and all applicable public disclosure requirements are observed.
Philanthropic contributions. Contributions are made only for bona fide charitable purposes and only where permitted by local law, never to obtain an unlawful business advantage.
Extortion. Any direct or indirect request for undue advantage by public officials, political actors or private sector employees is rejected.
Gifts, hospitality and entertainment. Offers or receipts are avoided whenever they could materially affect business decisions, are not reasonable and bona fide, or violate applicable law.
Reporting and response. Associates are required to report extortion attempts or bribery schemes and will not suffer demotion, penalty or other adverse consequences for refusing to pay bribes or for reporting alleged violations.
Accounts. FrontPace maintains complete and accurate financial records, ensuring that all transactions are properly, accurately and fairly recorded in a single set of books.
Communications and training. Annual training is made available for affiliates and key associates involved in sales, marketing and procurement.
Sanctions regime. FrontPace and its core resources adhere at all times to US OFAC and UK sanctions list regimes.