This is a corporate policy document designed to meet the standards of the Foreign Corrupt Practices Act, a provision of the Securities and Exchange Act of 1934. FCPA generally prohibits payments by companies and their representatives to foreign (i.e., non-U.S.) government and quasi-government officials to secure business.
Travis Texas Foreign Corrupt Practices Act (CPA) Corporate Policy is a comprehensive set of guidelines established by Travis Texas Corporation to ensure compliance with the CPA regulations. The CPA is a U.S. legislation enacted in 1977 that aims to prevent bribery and corruption by individuals and entities operating in international business transactions. The Travis Texas CPA Corporate Policy reflects the company's commitment to conducting business ethically, transparently, and in full compliance with the CPA. This policy outlines the procedures, standards, and controls that employees, agents, and consultants must adhere to when conducting business on behalf of the company abroad. It applies to all individuals associated with Travis Texas Corporation, irrespective of their position or role. The key elements covered under the Travis Texas CPA Corporate Policy include: 1. Anti-Bribery Provision: The policy explicitly prohibits offering, promising, authorizing, or providing anything of value directly or indirectly to foreign officials, political parties, or candidates to secure business advantages or improper influence. It emphasizes the importance of conducting business solely on fair, legitimate, and ethical grounds. 2. Accounting Controls: The policy includes provisions to maintain accurate books, records, and accounts that fairly reflect the company's transactions and assets. It stresses the need to avoid any falsification or misrepresentation of financial information. 3. Compliance Oversight: Travis Texas Corporation establishes a robust compliance framework to ensure adherence to the CPA. This includes designating a Compliance Officer responsible for overseeing compliance and promoting awareness through training programs and periodic assessments. 4. Third-Party Due Diligence: The policy requires rigorous due diligence to be conducted when engaging with third-party agents, consultants, or business partners. The company must evaluate their backgrounds and integrity to minimize risks associated with potential illegal activities or corruption. 5. Reporting Procedures: Employees are encouraged to promptly report any suspected violations of the CPA, company policy, or unethical conduct. The policy ensures the protection of whistleblowers and provides mechanisms for reporting concerns anonymously. It is also important to note that while the Travis Texas CPA Corporate Policy serves as a general framework, various specific policies can supplement it to address industry or region-specific nuances. These include policies tailored for high-risk countries, specific industries, or unique business operations where additional precautions are necessary to prevent corruption. In summary, the Travis Texas CPA Corporate Policy demonstrates the company's commitment to maintaining integrity, ensuring transparency, and preventing corruption in all its overseas operations. By implementing this policy, Travis Texas Corporation aims to promote a culture of ethical conduct, preserve its reputation, and contribute to a fair and level playing field in the global business landscape.
