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<back to Code of
Conduct
FOREIGN CORRUPT PRACTICES ACT COMPLIANCE POLICY
I. Purpose
The purpose of this Foreign Corrupt Practices Compliance Policy
(the "FCPA Policy") is to help ensure compliance by
TriMas Corporation and each subsidiary thereof (collectively,
"TriMas" or the "Company") with the Foreign
Corrupt Practices Act of 1977, as amended (the "FCPA").
The FCPA makes it illegal for U.S. persons, including U.S. companies
and their subsidiaries, officers, directors, employees and agents,
and any stockholders acting on their behalf, to bribe foreign
officials. The FCPA also requires U.S. companies and their subsidiaries
to keep accurate and complete books and records and to maintain
proper internal accounting controls. This Policy should be read
in conjunction with the Company's Code of Ethics and Business
Conduct.
All Company personnel are expected to conduct Company business
legally and ethically. The Company will conduct every international
business transaction with integrity, regardless of differing
local manners and traditions, and will comply with the laws
and regulations of the United States, particularly the provisions
of the Foreign Corrupt Practices Act (FCPA) and the laws and
regulations of each foreign country in which the Corporation
operates (except to the extent inconsistent with U.S. law).
II. Application
This FCPA Policy applies to all officers and employees of the
Company and its subsidiaries, both within and outside the U.S.,
and, by written agreement, flowing down all appropriate provisions
to all distributors, and to all consultants, representatives,
brokers or other persons or firms of U.S. or any other nationality
who have or are likely to have contact with a foreign customer
and are hired or otherwise retained by the Company to provide
services directly related to obtaining, retaining, or facilitating
business or business opportunities in or with any foreign country
or foreign firm ("third-party contractors").
III. Summary of the FCPA
The FCPA has two primary sections. The first section makes it
illegal to bribe foreign officials, and the second section imposes
record keeping and internal accounting requirements upon publicly
traded U.S. companies, like TriMas, and their subsidiaries.
A. Anti-bribery Provisions
1. Prohibited Payments
The FCPA's anti-bribery provisions make it illegal to bribe
foreign officials in order to obtain or retain business or to
secure any improper advantage. Specifically, the FCPA prohibits
payments, offers or gifts of money or anything of value, with
corrupt intent, to a "foreign official".
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