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I. Purpose

The purpose of this Policy is to ensure compliance by TECLOGISTICS and its directors, officers, employees, agents, consultants and representatives with the US Foreign Corrupt Practices Act (“FCPA”) and related laws of other countries in which TCL  does business.


1. Anti‑Bribery

The FCPA is a US Federal Statute prohibiting US companies and their officers, directors, employees and agents from:

  • giving, promising or offering anything of value, whether directly or indirectly, to
  • any foreign official  
  • with the intention of obtaining or retaining business or obtaining an improper business advantage

2. Record‑Keeping

The FCPA also requires US companies :

  • keep books and records that accurately reflect transactions and dispositions of assets and to
  • maintain a system of internal accounting controls

3. Penalties for Breach

Where the anti-bribery provisions of the FCPA are breached, the following penalties may be imposed:

  • Fines of up to US$2 million against the company
  • Prison terms of up to five years and fines of up to US$100,000 per violation for individuals involved

Willful violations of the record-keeping provisions may result in up to 20 years imprisonment and US$5 million fines for individuals and up to US$25 million for companies.

III. Policy

1. Prohibition of Bribery of Foreign Official

Under no circumstance shall any director, officer, employee, agent, consultant or representative give, pay, offer, promise to pay, or authorize the giving or payment of money or other thing of value to any foreign official or to any person while knowing or being aware of a probability that the payment or promise to pay is being made to or will be passed on to a foreign official.

2. Prohibition of Payment or Gift in Violation of Law

Under no circumstance shall any TLC person make, offer, promise, or authorize any payment or gift in violation of local law in any country.

3. Prohibition of Circumvention of Law

Under no circumstance shall any TLC  person enter into any transaction that is intended or designed to circumvent the laws of any country. Any transaction that has the appearance of circumventing the laws of any country must be avoided.

4. Prohibition of Lawful Payment without Prior Approval

Under no circumstance shall any TLC person offer, pay, promise or give any money or other thing of value to any foreign official without the prior written approval of the President and owner

5. Clarification of Uncertainty

Without prejudice to the foregoing requirement for written approval an TLC person must promptly contact the President when questions arise concerning the FCPA’s anti-bribery provisions including whether:

  • a particular individual or entity must be treated as a “foreign official”
  • whether something qualifies as anything of value
  • whether a proposed payment would be made or seen to be made to obtain, retain or direct business

6. Due Diligence and Third‑Party Certification

All persons must ensure that business relationships are formed only with reputable and qualified partners, agents and representatives. In negotiating any business relationship.

7. Record Keeping

All transactions involving TLC funds or assets should be recorded accurately and in reasonable detail.

8. Prohibition of Improper Accounting

Any  “improper transaction” or deviation from established  accounting practices, including omitted or falsified expense reports, is strictly prohibited.

9. Compulsory Compliance

Every person with TLC will comply with all specifications under the FCPA specifications

10. Chief Compliance Officer

The President /Owner is the Chief Compliance Officer FCPA matters. Any question regarding activities under consideration with regard to the FCPA or this Policy should be promptly directed to the President.

11. Zero Tolerance

TLC  will not tolerate any person that achieves or purports to achieve results  by violation of law or by acting dishonestly.


Josephine Treurniet