Anti-Bribery & Corruption Policy

At MadeLabs, we do not allow bribery or corruption, and are vigilant with regard to government interactions.

Introduction

MadeLabs is committed to conducting its business ethically and in compliance with all applicable laws and regulations, including the U.S. Foreign Corrupt Practices Act (FCPA), the United Kingdom Bribery Act (UKBA) and similar laws in other countries that prohibit improper payments to obtain a business advantage. This document describes MadeLabs' Policy prohibiting bribery and other improper payments in the conduct of MadeLabs business operations and employee responsibilities for ensuring implementation of the Policy. Questions about the Policy or its applicability to particular circumstances should be directed to Nicholas Barger, President.

Policy Overview

MadeLabs strictly prohibits bribery or other improper payments in any of its business operations. This prohibition applies to all business activities, anywhere in the world, whether involving government officials or other commercial enterprises. A bribe or other improper payment to secure a business advantage is never acceptable and can expose individuals and MadeLabs to possible criminal prosecution, reputational harm or other serious consequences. This Policy applies to everyone at MadeLabs, including all officers, employees and agents or other intermediaries acting on MadeLabs' behalf. Each officer and employee of MadeLabs has a personal responsibility and obligation to conduct MadeLabs' business activities ethically and in compliance with all applicable laws based on the countries wherein MadeLabs does business. Failure to do so may result in disciplinary action, up to and including dismissal. Improper payments prohibited by this policy include bribes, kickbacks, excessive gifts or entertainment, or any other payment made or offered to obtain an undue business advantage. These payments should not be confused with reasonable and limited expenditures for gifts, business entertainment and other legitimate activities directly related to the conduct of MadeLabs' business. Nicholas Barger, President is responsible for giving advice on the interpretation and application of this policy, supporting training and education, and responding to reported concerns.

The prohibition on bribery and other improper payments applies to all business activities, but is particularly important when dealing with government officials. The U.S. Foreign Corrupt Practices Act and similar laws in other countries strictly prohibit improper payments to gain a business advantage and impose severe penalties for violations. The following summary is intended to provide personnel engaged in international activities a basic familiarity with applicable rules so that inadvertent violations can be avoided and potential issues recognized in time to be properly addressed.

Common Questions About Anti-Bribery Laws

What do anti-bribery laws prohibit?

The FCPA, UKBA and other anti-bribery laws make it unlawful to bribe a foreign official to gain an "improper business advantage." An improper business advantage may involve efforts to obtain or retain business, as in the awarding of a government contract, but also can involve regulatory actions such as licensing or approvals. Examples of prohibited regulatory bribery include paying a foreign official to ignore an applicable customs requirement. A violation can occur even if an improper payment is only offered or promised and not actually made, it is made but fails to achieve the desired result, or the result benefits someone other than the giver (for example, directing business to a third party). Also, it does not matter that the foreign official may have suggested or demanded the bribe, or that a company feels that it is already entitled to the government action. Who is a "foreign official"? A "foreign official" can be essentially anyone who exercises governmental authority. This includes any officer or employee of a foreign government department or agency, whether in the executive, legislative or judicial branch of government, and whether at the national, state or local level. Officials and employees of government-owned or controlled enterprises also are covered, as are private citizens who act in an official governmental capacity. Foreign official status often will be apparent, but not always. In some instances, individuals may not consider themselves officials or be treated as such by their own governments but nevertheless exercise governmental authority under applicable anti-bribery laws. For example, an employee of a state-owned enterprise who has no formal government title might still be considered a "foreign official" because state ownership makes the enterprise an instrumentality of the government.