Each employee must adhere to the letter and spirit of all laws and regulations in effect where ICD does business. We are each responsible for knowing the laws applicable to the performance of our job.
BRIBES AND KICKBACKS: We will not condone any payment by any employee to any third party that is in the nature of a bribe, kickback for obtaining any business, or otherwise results in a special favor to ICD or its employees.
Gifts or payments may not be offered or given on behalf of ICD to any government official, political party, or candidate for public office either in the U.S. or abroad. These payments may be in violation of federal law and could result in the I mposition of fines or imprisonment or both.
GOVERNMENTAL INVESTIGATIONS AND LEGAL ACTIONS AND PROCEEDINGS: ICD’s policy is to cooperate fully with any governmental investigation and any legal action or proceeding. Appropriate handling of these matters is important for all of us as the laws regulating our business provide for civil and criminal penalties that may apply to ICD and its employees. If you receive a subpoena or any other legal document or are contacted by any person regarding a legal action, proceeding, or investigation that involves or may involve ICD, you must contact the Compliance Officer immediately.
Employees should never, under any circumstances, destroy or alter any ICD documents in anticipation of any investigation, action, or proceeding or in anticipation of a request for those documents from any governmental agency, court, or participant in any action or proceeding. In addition, employees should never lie, make any misleading statements, or attempt to cause any other ICD employee or any other person to fail to provide information or to provide any false or misleading information in connection with any investigation, action, or proceeding.
Any questions regarding the propriety of destroying or altering ICD documents should be referred immediately to the Compliance Officer.
FAIR DEALING: We seek to outperform our competition fairly and honestly. Each employee should respect the rights of and deal fairly and honestly with ICD’s suppliers, customers, competitors, and vendors. Stealing proprietary or confidential information or possessing trade secret information that was obtained without the owner’s consent is prohibited.
PAYMENTS TO GOVERNMENT OFFICIALS: The laws of the U.S. and foreign countries prohibit companies and their employees and representatives from offering, promising to pay, or authorizing payment of any money or anything of value to any government official, any political party or official, or any candidate for political office, for the purpose of influencing any act or decision of that official, party, or candidate in his or its official capacity. Companies and their employees and representatives are also prohibited from taking any of these actions for the purpose of inducing the official, party, or candidate to use his or its influence to affect or influence any act or decision of a government or any agency thereof.
The U.S. Foreign Corrupt Practices Act (“FCPA”) prohibits bribery or unlawful payments to any official or employee of a foreign government or agency for the purpose of influencing decisions or obtaining or retaining business.
ICD requires full and absolute compliance with the FCPA by all of its employees, representatives, and distributors. If you become aware of any FCPA violation or potential violation, you must immediately notify the CEO and the Compliance Officer.
Political Contributions: Generally, U.S. and foreign laws prohibit corporations from making contributions or expenditures in connection with any election for political office. These laws also prohibit corporations from financially supporting political candidates. Political contributions include direct or indirect payments, advances, gifts of goods or services, subscriptions, memberships, purchase of tickets for fundraisers, and purchase of advertising space. No employee shall make any political contribution or other expenditure to any political organization or candidate for political office on behalf of or for the benefit of ICD.
ANTITRUST AND COMPETITION LAWS: Antitrust and competition laws regulate ICD’s relationships with its vendors, customers, and competitors. While these laws are complex and broad, generally, they prohibit agreements, arrangements, and activities that may have the effect of reducing competition. ICD is committed to free and competitive markets. No employee may enter into any agreement or arrangement, or engage in any activity, with vendors, customers, or competitors that may lessen competition.
HEALTH, SAFETY, AND THE ENVIRONMENT: ICD is committed to protecting the health and safety of our employees and to environmental stewardship. Working safely and protecting others and the environment are conditions of employment at ICD.
