CAT® SIMULATORS

Anti-Corruption Policy

Purpose and Scope

This Anti-Corruption Policy establishes the standards and requirements applicable to all parties, employees, officers, directors, agents, representatives, subcontractors, consultants, and any other persons acting on behalf of a party in connection with any business relationship, agreement, transaction, or engagement. The purpose of this Policy is to ensure compliance with all applicable anti-corruption and anti-bribery laws and regualtions and to prohibit any forms of bribery, corruption, or improper business conduct. 

Compliance with Applicable Laws

Each party represents, warrants, and covenants that it is familiar with, is in compliance with, and shall remain in compliance with all applicable anti-corruption and anti-bribery laws, regulations, and governmental requirements, including, without limitation, the United States Foreign Corrupt Practices Act of 1977, as amended (the “FCPA”), the United Kingdom Bribery Act 2010, and any other applicable laws relating tot he prevention of corruption, bribery, fraud, or unethical business practices. 

Prohibited Conduct

  1. No party, nor any of its employees, officers, directors, agents, representatives, affiliates, subcontractors, or other persons acting on its behalf, shall directly or indirectly: 
  2. Offer, promise, authorize, provide, solicit, receive, or accept any payment, gift, gratuity, entertainment, hospitality, favor, benefit, or anything of value that would constitute an unlawful, improper, or corrupt practice.
  3. Make or authorize any payment or transfer of value to any government official, foreign official, political candidate, public international organization, or any other person of the purpose of:
    1. Influencing any act or decision in an official capacity;
    2. Inducing any person to act or refrain from acting in violation of a lawful duty;
    3. Securing an improper advantage; or
    4. Obtaining, retaining, directing, or facilitating business or business opportunity.
  4. Engage in any conduct that would cause another party to violate applicable anti-corruption or anti-bribery laws.
  5. use third parties, intermediaries, consultants, distributors, agents, or subcontractors to undertake any activity prohibited by this policy.

Books, Records, and Internal Controls

Each party shall maintain accurate books, records, accounts, and supporting documentation that fairly and accurately reflect all transactions and expenditures. Each party shall implement and maintain appropriate internal controls, policies, procedures, and compliance measures reasonably designed to prevent, detect, and address violations of this Policy and applicable anti-corruption laws. 

Reporting Obligations

Each party shall promptly notify the other party upon becoming aware of: 

  • Any actual, suspected, or alleged violation of this Policy or application anti-corruption laws;
  • Any request, demand, solicitation, or offer involving an improper payment, bribe, kickback, facilitation payment, or other undue financial or business advantage; or
  • Any governmental investigation, inquiry, enforcement action, or proceeding relating to anti-corruption compliance that may affect the parties’ business relationship. 

Cooperation and Remediation

Each party agrees to cooperate in good faith with any reasonable investigation relating to potential violations of this Policy. Appropriate corrective actions shall be taken promptly to address any confirmed non-compliance. 

Termination and Remedies

Any violation of this Policy shall constitute a material breach of the application agreement or business relationship. Upon such violation, the non-breaching party may immediately terminate the applicable agreement, engagement, or relationship without liability, in addition to pursuing any other rights, remedies, damages, or relief available at law, in equity, or under contract. 

Certification

Each party acknowledges its commitment to conducting business ethically and in compliance with all applicable anti-corruption laws and agrees to adhere to the requirements set forth in this Policy at all times. 

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