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government, TriMas employees should seek advice
from the Company Legal Department prior to giving a gift to
or entertaining any U.S. government employee.
Antitrust
The Company is subject to antitrust and competition laws
in most countries in which it does business, and the investigation
and enforcement of antitrust laws is more and more the result
of international cooperation among enforcement authorities.
In general, most antitrust laws in effect where the Company
does business prohibit agreements or actions that may restrain
trade or reduce competition. Violations include agreements among
competitors to fix or control prices; boycotts of specified
suppliers or customers; efforts to misrepresent, disparage or
harass competitors; coordination with competitors to allocate
products, territories or markets; competitor agreements to limit
the production or sale of products for anticompetitive purposes;
price discrimination; tie-in sales or certain other restrictive
agreements with suppliers and customers; and certain exclusive
dealings arrangements. Special care must be exercised to ensure
that any activities undertaken with representatives of other
companies, particularly our competitors, are not viewed and
would not be construed as violations of any antitrust laws.
The antitrust laws are complex and their requirements are not
always obvious. The Company has adopted guidelines to assist
employees with their understanding of the antitrust laws. However,
questions about a particular situation should be directed to
the Company Legal Department before you take any action.
Anti-Boycott
The United States has enacted laws that prohibit or penalize
participation in international boycotts that the United States
government does not sanction, specifically the Arab boycott
of Israel. A boycott occurs when a person or group of persons
refuse to do business with certain other people or countries.
U.S. law imposes reporting requirements regarding any requests
to participate in any unsanctioned boycott. These laws apply
to entities organized under U.S. law and to U.S. nationals or
residents employed by such entities, but do not apply to U.S.
nationals working for a non-U.S. company and residing outside
of the U.S. All employees, whether subject to the U.S. laws
or otherwise, must refer any request to participate in any such
boycott to the Company Legal Department in advance of taking
any action regarding such request.
International Sanctions and Trade Embargoes
The United States has imposed a number of unilateral trade
sanctions that restrict trade with certain specified countries,
persons and entities. These restrictions may apply whether the
trading takes place from the United States or otherwise. The
U.S. trade restrictions apply to U.S. citizens and residents,
including U.S. companies, and, in certain regards, to foreign
subsidiaries of U.S. companies. The countries of Burma (Myanmar),
Cuba, Iran, Iraq, Liberia, Libya, North Korea, Sudan and Syria
are currently subject to U.S. trade restrictions as are certain
individuals and entities in the Balkans, Cote d'Ivoire, Liberia
and Zimbabwe, and all individuals and entities listed on the
Specially Designated Nationals List. Because this listing may
not include all countries subject to restrictions and is subject
to change at any time, employees must check appropriate information
sources (such as governmental websites) in advance of making
any contractual commitments. Any employee contemplating doing
business with national or public or private sector persons from
such countries must obtain the prior approval of Company management
and the Company Legal Department.
Export Control
Employees must comply with all applicable national and multinational
export control laws. For example, under U.S. export control
laws, the export or re-export of certain controlled commodities
and technology from the U.S. to another country requires a validated
export license. Under certain circumstances, these laws also
prohibit subsidiaries of U.S. companies, including those located
outside the United States, from dealing directly or indirectly
without an export license. In addition, regardless of the country
in which you are working, U.S. export control laws apply to:
(1) the re-export of certain U.S. origin-commodities and technical
data from countries outside the U.S.; (2) U.S. origin parts
and components used in the manufacture of a non-U.S. end-product
for export or re-export and; (3) non-U.S.-produced products
that incorporate U.S.-origin technical data. Further, the disclosure
of technical information to a foreign national, including employees,
whether in the U.S. or elsewhere in the world, may be subject
to export controls. Any questions or uncertainty regarding compliance
with export controls should be brought to the attention of the
Company Legal Department.
Customs
Customs laws, which apply to intracompany as well as third-party
transactions, require employees of the Company to determine
the correct classification, value and country of origin of all
its imports. As an importer, we must be able to demonstrate
by a documented, auditable trail that the Company exercised
reasonable care to ensure that its imports comply with all applicable
laws. This requires, at a minimum, the reporting of complete,
accurate and detailed information regarding any imported product,
its place (or places) of manufacture and its full cost. While
specific rules may vary, virtually all countries in which we
do business share these requirements. Violations are punishable
by civil and criminal penalties.
Foreign Corrupt Practices Act ( more
information> )
The Foreign Corrupt Practices Act (FCPA) prohibits the payment
or offer of money, or anything of value, by or on behalf of
U.S. companies (and their subsidiaries) outside the United States
to foreign government officials, political officials or candidates,
and officials of public international organizations (e.g., the
United Nations, International Monetary Fund or World Bank) for
the purpose of securing or retaining businesses. Certain small,
facilitating payments for the purpose of obtaining routine,
non-discretionary governmental services are permitted under
the FCPA. Employees should consult the Company's FCPA Compliance
Policy for further guidance on the prohibitions and requirements
of the FCPA and obtain written approval of the Company's Legal
Department prior to making any facilitating payment to a foreign
official. In addition, the FCPA requires the Company to use
proper accounting controls and maintain accurate, reasonably
detailed books and records of all
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