Satisfaction
It is Filtervac International Inc. policy to comply with all applicable anti-bribery laws, including the U.S. Foreign Corrupt Practices Act and all applicable local laws where Filtervac International Inc. operates, and to accurately reflect all transactions on Filtervac International Inc.`s books and records.

It is also Filtervac International Inc.`s policy to require those agents, consultants and business partners who work on Filtervac International Inc.`s behalf before Government Officials to comply with these same laws and practices.

What It Means
Filtervac International Inc. requires that:

Its employees not engage in acts or omissions that offer, authorize or give a bribe to a Government Official, or create the impression that a bribe has been offered, authorized or given;
Its employees take affirmative steps to prevent those doing business directly or indirectly before a Government Official on Filtervac International Inc.`s behalf from engaging in bribery;
Its employees adhere to Filtervac International Inc.`s mandatory due diligence, internal approval, financial reporting, and document retention requirements in the six key areas listed below;
Its employees scrutinize activities of certain acquisition targets and joint venture partners to identify and address potential bribery issues;
Its employees promptly report to Filtervac International Inc. any suspected violations by Filtervac International Inc. employees or others doing business before a Government Official on Filtervac International Inc.`s behalf; and
Its auditing function audit Filtervac International Inc.`s businesses as appropriate for potential bribery activities and risks.

Six Key Areas
In addition to those obligations set forth above, Filtervac International Inc. requires specific due diligence, internal legal and business approvals, financial reporting, and document retention requirements in six key areas:

Filtervac International Inc. sponsorship of any travel-related benefits for any Government Official
Gifts to, entertainment for, or charitable contributions on behalf of any Government Official
Use of consultants and sales agents who may interact with Government Officials on Filtervac International Inc.`s behalf
Facilitating or "grease" payments to any Government Official
Activities with certain business partners who may interact with Government Officials directly or indirectly on Filtervac International Inc.`s behalf
Political contributions to any Government Official, political party, candidate or political organization.

What to Avoid

The direct or indirect provision of cash or anything of value to a Government Official to obtain an unfair business advantage or to obtain or retain business.
Authorizing or providing travel benefits, gifts, entertainment, or political contributions for the benefit of a Government Official without the required due diligence assessment and internal Filtervac International Inc. business and legal approvals.
Entering into a consultant or sales agent agreement that will result in contacts with Government Officials without conducting due diligence, obtaining the required internal business and legal approvals, retaining all due diligence for eight years, and accurately recording on Filtervac International Inc.`s book and records all related payments.
Making any "grease" or facilitating payments without obtaining the required Filtervac International Inc. internal business and legal approvals.
Making any incomplete, false or inaccurate entries on Filtervac International Inc.`s books and records

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