Anti-Bribery & Anti-Corruption Policy

Updated February 13, 2018

Imago Inc. (or the “Company”) is committed to conducting our business in accordance with all applicable laws, rules and regulations and the highest ethical standards, and this commitment is embodied in the Code of Business Conduct and Ethics.

The purpose of this Anti-Bribery and Anti-Corruption Policy is to reiterate Imago’s commitment to full compliance by the Company and its officers, directors, employees and agents with the U.S. Foreign Corrupt Practices Act (“FCPA”), and any local anti-bribery or anti-corruption laws that may be applicable. This Policy supplements the Code of Business Conduct and Ethics and all applicable laws and provides guidelines for compliance with the FCPA, and Company policies applicable to Imago’s operations world-wide.

For the purposes of this Policy, a “contractor” or “supplier” is defined as a third-party entity or individual who provides, and receives payment for, services or goods related to any aspect of Imago, and includes consultants and subcontractors. A “non-supplier vendor” is defined as a third-party individual, company, organization, and/or Government or Government related entity that will receive payment from Imago but will not provide goods or services in return.

This Policy is applicable to every employee of Imago, including senior executive and financial officers, and to members of the Imago Board of Directors. The reporting requirement of this Policy is also applicable to Imago’s contractors and suppliers. This Policy is intended to supplement all applicable laws, rules, and other corporate policies. It is not intended to supplant any local laws.

Corruption is the misuse of public power for private profit, or the misuse of entrusted power for private gain. Bribery is the offer, promise, or payment of cash, gifts, or even excessive entertainment, or an inducement of any kind offered or given to a person in a position of trust to influence that person’s views or conduct or to obtain an improper advantage. Bribery and corruption can take many forms, including the provision or acceptance of:

Cash payments;
Phony jobs or “consulting” relationships;
Political contributions;
Charitable contributions;
Social benefits; or
Gifts, travel, hospitality, and reimbursement of expenses.
Imago personnel and agents are strictly prohibited from offering, paying, promising, or authorizing:

any payment or other thing of value;
to any person;
directly or indirectly through or to a third party;
for the purpose of (i.e., in exchange for);
causing the person to act or fail to act in violation of a legal duty;
causing the person to abuse or misuse their position; or
securing an improper advantage, contract or concession;
for Imago or any other party.
(“Improper Payment Activity”)

To promote compliance with anti-corruption laws in the United States, and other applicable jurisdictions, no Imago personnel shall undertake any Improper Payment Activity in respect of a foreign official, a domestic official, or a person doing business in the private sector.

In addition, Imago’s books and records must correctly record both the amount and a written description of any transaction. Imago personnel must ensure that there is a reasonable relationship between the substance of a transaction and how it is described in the Company’s books and records.

Other Imago policies impacted by, and which should be construed consistent with this Policy, include the Code of Business Conduct and Ethics, the Code of Business Conduct Escalation Procedure, Procedures for Implementing the Anti-Bribery and Anti-Corruption Policy, the Vendor On-Boarding Standard, and the Supplier Code of Ethics.

There is no permitted deviation or waiver from this Policy.

Any employee who violates the terms of this Policy will be subject to disciplinary action. Any employee who has direct knowledge of potential violations of this Policy but fails to report such potential violations to Company management will be subject to disciplinary action. Any employee who misleads or hinders investigators inquiring into potential violations of this Policy will be subject to disciplinary action. In all cases, disciplinary action may include termination of employment. Any third party agent who violates the terms of this Policy, who knows of and fails to report to Imago management potential violations of this Policy, or who misleads investigators making inquiries into potential violations of this Policy, may have their contracts re-evaluated or terminated.


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