In the conduct of Group Lamerica, L.L.C. (“Group Lamerica” or “Company”) business, which at times includes acting on behalf of our clients or at their direction, the Company can be exposed to situations that may give rise to the possibility of Improper Transactions (also referred to in some contexts as Sensitive Transactions).
- Improper Transactions can encompass a broad range of business dealings that are generally considered illegal, unethical, immoral, or possibly reflecting unfavorably on the integrity of the Company, its management, employees, associates and agents, and its clients.
- Such Improper Transactions are usually in the nature of direct or indirect kickbacks, bribes, or payoffs to influence favorably a decision affecting a company's business or for the personal gain of an officer, employee or some other related party.
- Improper Transactions may result in violation of federal laws such as domestic anti-bribery laws, mail fraud and wire fraud statutes, anti-racketeering statutes, the Foreign Corrupt Practices Act, and other state laws or laws of foreign countries in which Group Lamerica operates in the course of conducting our business and client engagements. If violations occur, the Company and its officers and members, as well as employees and Company clients involved, may be subject to fines, imprisonment, and civil litigation.
The Company, its officers, members, employees, third-party contractors, agents, brokers and individuals and firms hired or retained by the Company are expected to conduct our business and our client engagements legally, ethically and with integrity, regardless of differing local cultures, practices and traditions.
Each office and operation of Group Lamerica is expected to comply with and is responsible for compliance with all applicable Group Lamerica policies, including this Group Lamerica Corrupt Practices Compliance Policy (“Compliance Policy”). No violation of the letter and spirit of federal, state, or foreign laws will be permitted or tolerated, particularly the provisions of the US Foreign Corrupt Practices Act of 1977, as amended (“FCPA”).
This Compliance Policy applies to all consultants, contracted associates, representatives, brokers or other persons or firms who are likely to have contact with a foreign party, and are hired or otherwise retained by the Company to provide services directly related to a Group Lamerica business activity or client engagement.