We Have a Zero Tolerance Policy for Bribery and Corrupt Activities

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Aprimo Anti-Bribery & Anti-Corruption Policy

Revised December 2017

1. What does your policy cover?

This anti-bribery and anti-corruption policy exists to set out the responsibilities of Aprimo US LLC and its affiliates (“Aprimo”), and those who work for us in regards to observing and upholding our zero-tolerance policy on bribery and corruption.

It also exists to act as a source of information and guidance for those working for Aprimo. It helps them recognize and handle bribery and corruption issues, as well as understand their responsibilities.

2. Policy Statement

Aprimo is committed to conducting business in an ethical and honest manner, and is committed to implementing and enforcing systems that ensure bribery is prevented. Aprimo has zero tolerance for bribery and corrupt activities. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever in the world we operate.

Aprimo will constantly uphold all laws relating to anti-bribery and corruption in all the jurisdiction in which we operate. We are bound by the laws of the respective jurisdictions in which our operations reside (including the U.S. Foreign Corrupt Practices Act of 1977 and the UK Bribery Act of 2010), in regards to our conduct both at home and abroad.

Aprimo recognizes that bribery and corruption are punishable by imprisonment and a fine. If our company is discovered to have taken part in corrupt activities, we may be subjected to fines, be excluded from public contracts, and face serious damage to our reputation. It is with this in mind that we commit to preventing bribery and corruption in our business, and take our legal responsibilities seriously.

3. Who is covered by the policy?

This anti-bribery and anti-corruption policy applies to all employees (whether temporary, fixed-term, or permanent) of any and all of Aprimo’s affiliates, including officers. Aprimo’s contractors are established providers of information technology throughout the world with robust anti-bribery and anti-corruption policies.

4. Definition of bribery

Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting or soliciting something of value or of an advantage so to induce or influence an action or decision. A bribe refers to any inducement, reward, or object/item of value offered to another individual in order to gain commercial, contractual, regulatory, or personal advantage. Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law.

Bribery is illegal. Employees must not engage in any form of bribery, whether it be directly, passively (as described above), or through a third party (such as an agent or distributor). They must not bribe a foreign public official anywhere in the world. They must not accept bribes in any degree and if they are uncertain about whether something is a bribe or a gift or act of hospitality, they must seek further advice from the Sr. Vice President of Human Resources.

5. What is and what is NOT acceptable

This section of the policy refers to four areas:

  • gifts and hospitality
  • facilitation payments
  • political contributions
  • charitable contributions

Gifts and hospitality

Aprimo and its employees accept normal and appropriate gestures of hospitality and goodwill (whether given to/received from third parties) so long as the giving or receiving of gifts meets the following requirements:

  • It is not made as an explicit exchange for favors or benefits.
  • It is not made with the suggestion that a return favor is expected.
  • It is in compliance with local law.
  • It is given in the name of the company, not in an individual’s name.
  • It is appropriate for the circumstances (e.g. giving small gifts around holidays or as a small thank you to a company for helping with a large project upon completion).
  • It is of an appropriate type and value and given at an appropriate time, taking into account the reason for the gift.
  • It is given/received openly, not secretly.
  • It is not above a certain excessive value.
  • It is not offered to, or accepted from, a government official or representative or politician or political party, without the prior approval of the Sr. Vice President of Human Resources.

Where it is inappropriate to decline the offer of a gift (i.e. when meeting with an individual of a certain religion/culture who may take offense), the gift may be accepted so long as it is declared to the Sr. Vice President of Human Resources, who will assess the circumstances.

Aprimo recognizes that the practice of giving and receiving business gifts varies between countries, regions, cultures, and religions, so definitions of what is acceptable and not acceptable will inevitably differ for each. The intention behind a gift being given/received should always be considered. If there is any uncertainty, the advice of the Sr. Vice President of Human Resources should be sought.

Facilitation Payments

Aprimo does not accept and will not make any form of facilitation payments of any nature. We recognize that facilitation payments are a form of bribery that involves expediting or facilitating the performance of a public official for a routine governmental action. We recognize that they tend to be made by low-level officials with the intention of securing or speeding up the performance of a certain duty or action.

Aprimo does not allow kickbacks to be made or accepted. We recognize that kickbacks are typically made in exchange for a business favor or advantage.

Political Contributions

Aprimo will not make any donations, whether in cash, kind, or by any other means, to support any political parties or candidates. We recognize this may be perceived as an attempt to gain an improper business advantage.

Charitable Contributions

Aprimo accepts (and indeed encourages) the act of donating to charities, whether through services, knowledge, time, or direct financial contributions (cash or otherwise). Employees must be careful to ensure that charitable contributions are not used to facilitate and conceal acts of bribery. We will ensure that all charitable donations made are legal and ethical under local laws and practices, and that donations are not offered/made without the approval of the Sr. Vice President of Human Resources.

6. Employee Responsibilities

As an employee of Aprimo, you must ensure that you read, understand, and comply with the information contained within this policy, and with any training or anti-bribery and anti-corruption information you are given.

All employees and those under our control are equally responsible for the prevention, detection, and reporting of bribery and other forms of corruption. They are required to avoid any activities that could lead to, or imply, a breach of this anti-bribery policy.

If you have reason to believe or suspect that an instance of bribery or corruption has occurred or will occur in the future that breaches this policy, you must notify the Sr. Vice President of Human Resources. If any employee breaches this policy, they will face disciplinary action and could face dismissal for gross misconduct. Aprimo has the right to terminate any (contractual or at-will) relationship with an employee if they breach this anti-bribery policy.

7. What happens if I need to raise a concern?

This section of the policy covers three areas:

  • how to raise a concern
  • what to do if you are a victim of bribery or corruption
  • protection

How to raise a concern

If you suspect that there is an instance of bribery or corrupt activities occurring in relation to Aprimo, you are encouraged to raise your concerns at as early a stage as possible. If you’re uncertain about whether a certain action or behavior can be considered bribery or corruption, you should speak to your direct manager, the Sr. Vice President of Human Resources, or call the Aprimo Employee Hotline.

Aprimo will familiarize all employees with its whistleblowing procedures so employees can vocalize their concerns swiftly and confidentially. Aprimo has established a confidential Aprimo Employee Hotline to report all concerns including bribery or other ethical questions. All new hires receive the contact information within the first days of employment and such information is also posted on the company intranet.

What to do if you are a victim of bribery or corruption

You must tell your direct manager as soon as possible if you are offered a bribe by anyone, if you are asked to make one, if you suspect that you may be bribed or asked to make a bribe in the near future, or if you have reason to believe that you are a victim of another corrupt activity.

Protection

If you refuse to accept or offer a bribe or you report a concern relating to potential act(s) of bribery or corruption, Aprimo understands that you may feel worried about potential repercussions. Aprimo will support anyone who raises concerns in good faith under this policy, even if investigation finds that they were mistaken.

Aprimo will ensure that no one suffers any detrimental treatment as a result of refusing to accept or offer a bribe or other corrupt activities or because they reported a concern relating to potential act(s) of bribery or corruption. Detrimental treatment refers to dismissal, disciplinary action, threats, or unfavorable treatment in relation to the concern the individual raised.

If you have reason to believe you’ve been subjected to unjust treatment as a result of a concern or refusal to accept a bribe, you should inform your direct manager, Human Resources or report to the confidential Aprimo Employee Hotline immediately.

8. Training and communication

Aprimo will provide training on this policy as part of the on-boarding process for all new employees. Employees will also receive regular, relevant training on how to adhere to this policy and will be asked to formally accept that they will comply with this policy.

Aprimo’s anti-bribery and corruption policy and zero-tolerance attitude will be clearly communicated to all suppliers, contractors, business partners, and any third-parties at the outset of business relations, and as appropriate thereafter.

Aprimo will provide relevant anti-bribery and anti-corruption training to employees where we feel their knowledge of how to comply with the relevant anti-bribery laws and regulations needs to be enhanced.

9. Record keeping

Aprimo will keep detailed and accurate financial records, and will have appropriate internal controls in place to act as evidence for all payments made. We will declare and keep a written record of the amount and reason for hospitality or gifts accepted and given, and understand that gifts and acts of hospitality are subject to managerial review.

10. Monitoring and reviewing

Aprimo’s managers, executives and Sr. Vice President of Human Resources are responsible for monitoring the effectiveness of this policy and will review the implementation of it on a regular basis. They will assess its suitability, adequacy, and effectiveness.

Any need for improvements will be applied as soon as reasonably possible. Employees are encouraged to offer their feedback on this policy if they have any suggestions for how it may be improved. Feedback of this nature should be addressed to the Sr. Vice President of Human Resources.

This policy may be amended at any time so as to improve its effectiveness at combating bribery and corruption.



Aprimo US LLC
v12.17

Aprimo Anti-Bribery & Anti-Corruption Policy

Revised December 2017

1. What does your policy cover?

This anti-bribery and anti-corruption policy exists to set out the responsibilities of Aprimo US LLC and its affiliates (“Aprimo”), and those who work for us in regards to observing and upholding our zero-tolerance policy on bribery and corruption.

It also exists to act as a source of information and guidance for those working for Aprimo. It helps them recognize and handle bribery and corruption issues, as well as understand their responsibilities.

2. Policy Statement

Aprimo is committed to conducting business in an ethical and honest manner, and is committed to implementing and enforcing systems that ensure bribery is prevented. Aprimo has zero tolerance for bribery and corrupt activities. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever in the world we operate.

Aprimo will constantly uphold all laws relating to anti-bribery and corruption in all the jurisdiction in which we operate. We are bound by the laws of the respective jurisdictions in which our operations reside (including the U.S. Foreign Corrupt Practices Act of 1977 and the UK Bribery Act of 2010), in regards to our conduct both at home and abroad.

Aprimo recognizes that bribery and corruption are punishable by imprisonment and a fine. If our company is discovered to have taken part in corrupt activities, we may be subjected to fines, be excluded from public contracts, and face serious damage to our reputation. It is with this in mind that we commit to preventing bribery and corruption in our business, and take our legal responsibilities seriously.

3. Who is covered by the policy?

This anti-bribery and anti-corruption policy applies to all employees (whether temporary, fixed-term, or permanent) of any and all of Aprimo’s affiliates, including officers. Aprimo’s contractors are established providers of information technology throughout the world with robust anti-bribery and anti-corruption policies.

4. Definition of bribery

Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting or soliciting something of value or of an advantage so to induce or influence an action or decision. A bribe refers to any inducement, reward, or object/item of value offered to another individual in order to gain commercial, contractual, regulatory, or personal advantage. Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law.

Bribery is illegal. Employees must not engage in any form of bribery, whether it be directly, passively (as described above), or through a third party (such as an agent or distributor). They must not bribe a foreign public official anywhere in the world. They must not accept bribes in any degree and if they are uncertain about whether something is a bribe or a gift or act of hospitality, they must seek further advice from the Sr. Vice President of Human Resources.

5. What is and what is NOT acceptable

This section of the policy refers to four areas:

  • gifts and hospitality
  • facilitation payments
  • political contributions
  • charitable contributions

Gifts and hospitality

Aprimo and its employees accept normal and appropriate gestures of hospitality and goodwill (whether given to/received from third parties) so long as the giving or receiving of gifts meets the following requirements:

  • It is not made as an explicit exchange for favors or benefits.
  • It is not made with the suggestion that a return favor is expected.
  • It is in compliance with local law.
  • It is given in the name of the company, not in an individual’s name.
  • It is appropriate for the circumstances (e.g. giving small gifts around holidays or as a small thank you to a company for helping with a large project upon completion).
  • It is of an appropriate type and value and given at an appropriate time, taking into account the reason for the gift.
  • It is given/received openly, not secretly.
  • It is not above a certain excessive value.
  • It is not offered to, or accepted from, a government official or representative or politician or political party, without the prior approval of the Sr. Vice President of Human Resources.

Where it is inappropriate to decline the offer of a gift (i.e. when meeting with an individual of a certain religion/culture who may take offense), the gift may be accepted so long as it is declared to the Sr. Vice President of Human Resources, who will assess the circumstances.

Aprimo recognizes that the practice of giving and receiving business gifts varies between countries, regions, cultures, and religions, so definitions of what is acceptable and not acceptable will inevitably differ for each. The intention behind a gift being given/received should always be considered. If there is any uncertainty, the advice of the Sr. Vice President of Human Resources should be sought.

Facilitation Payments

Aprimo does not accept and will not make any form of facilitation payments of any nature. We recognize that facilitation payments are a form of bribery that involves expediting or facilitating the performance of a public official for a routine governmental action. We recognize that they tend to be made by low-level officials with the intention of securing or speeding up the performance of a certain duty or action.

Aprimo does not allow kickbacks to be made or accepted. We recognize that kickbacks are typically made in exchange for a business favor or advantage.

Political Contributions

Aprimo will not make any donations, whether in cash, kind, or by any other means, to support any political parties or candidates. We recognize this may be perceived as an attempt to gain an improper business advantage.

Charitable Contributions

Aprimo accepts (and indeed encourages) the act of donating to charities, whether through services, knowledge, time, or direct financial contributions (cash or otherwise). Employees must be careful to ensure that charitable contributions are not used to facilitate and conceal acts of bribery. We will ensure that all charitable donations made are legal and ethical under local laws and practices, and that donations are not offered/made without the approval of the Sr. Vice President of Human Resources.

6. Employee Responsibilities

As an employee of Aprimo, you must ensure that you read, understand, and comply with the information contained within this policy, and with any training or anti-bribery and anti-corruption information you are given.

All employees and those under our control are equally responsible for the prevention, detection, and reporting of bribery and other forms of corruption. They are required to avoid any activities that could lead to, or imply, a breach of this anti-bribery policy.

If you have reason to believe or suspect that an instance of bribery or corruption has occurred or will occur in the future that breaches this policy, you must notify the Sr. Vice President of Human Resources. If any employee breaches this policy, they will face disciplinary action and could face dismissal for gross misconduct. Aprimo has the right to terminate any (contractual or at-will) relationship with an employee if they breach this anti-bribery policy.

7. What happens if I need to raise a concern?

This section of the policy covers three areas:

  • how to raise a concern
  • what to do if you are a victim of bribery or corruption
  • protection

How to raise a concern

If you suspect that there is an instance of bribery or corrupt activities occurring in relation to Aprimo, you are encouraged to raise your concerns at as early a stage as possible. If you’re uncertain about whether a certain action or behavior can be considered bribery or corruption, you should speak to your direct manager, the Sr. Vice President of Human Resources, or call the Aprimo Employee Hotline.

Aprimo will familiarize all employees with its whistleblowing procedures so employees can vocalize their concerns swiftly and confidentially. Aprimo has established a confidential Aprimo Employee Hotline to report all concerns including bribery or other ethical questions. All new hires receive the contact information within the first days of employment and such information is also posted on the company intranet.

What to do if you are a victim of bribery or corruption

You must tell your direct manager as soon as possible if you are offered a bribe by anyone, if you are asked to make one, if you suspect that you may be bribed or asked to make a bribe in the near future, or if you have reason to believe that you are a victim of another corrupt activity.

Protection

If you refuse to accept or offer a bribe or you report a concern relating to potential act(s) of bribery or corruption, Aprimo understands that you may feel worried about potential repercussions. Aprimo will support anyone who raises concerns in good faith under this policy, even if investigation finds that they were mistaken.

Aprimo will ensure that no one suffers any detrimental treatment as a result of refusing to accept or offer a bribe or other corrupt activities or because they reported a concern relating to potential act(s) of bribery or corruption. Detrimental treatment refers to dismissal, disciplinary action, threats, or unfavorable treatment in relation to the concern the individual raised.

If you have reason to believe you’ve been subjected to unjust treatment as a result of a concern or refusal to accept a bribe, you should inform your direct manager, Human Resources or report to the confidential Aprimo Employee Hotline immediately.

8. Training and communication

Aprimo will provide training on this policy as part of the on-boarding process for all new employees. Employees will also receive regular, relevant training on how to adhere to this policy and will be asked to formally accept that they will comply with this policy.

Aprimo’s anti-bribery and corruption policy and zero-tolerance attitude will be clearly communicated to all suppliers, contractors, business partners, and any third-parties at the outset of business relations, and as appropriate thereafter.

Aprimo will provide relevant anti-bribery and anti-corruption training to employees where we feel their knowledge of how to comply with the relevant anti-bribery laws and regulations needs to be enhanced.

9. Record keeping

Aprimo will keep detailed and accurate financial records, and will have appropriate internal controls in place to act as evidence for all payments made. We will declare and keep a written record of the amount and reason for hospitality or gifts accepted and given, and understand that gifts and acts of hospitality are subject to managerial review.

10. Monitoring and reviewing

Aprimo’s managers, executives and Sr. Vice President of Human Resources are responsible for monitoring the effectiveness of this policy and will review the implementation of it on a regular basis. They will assess its suitability, adequacy, and effectiveness.

Any need for improvements will be applied as soon as reasonably possible. Employees are encouraged to offer their feedback on this policy if they have any suggestions for how it may be improved. Feedback of this nature should be addressed to the Sr. Vice President of Human Resources.

This policy may be amended at any time so as to improve its effectiveness at combating bribery and corruption.



Aprimo US LLC
v12.17

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