Improper Payments Prevention We do not engage in bribery or corruption of any kind.
THE GE WAY POLICY SPOTLIGHT
Bribery concerns are not limited to government officials – many countries and companies also prohibit bribery in the private sector. Gifts, entertainment or anything else of value provided in exchange for improper assistance or consideration could be viewed as a bribe.
• GE prohibits bribery in all business dealings, in every country around the world, with both governments and the private sector.
• We maintain strong controls aimed at preventing and detecting bribery. This includes a rigorous process for appointing and managing third parties acting on GE’s behalf in business dealings.
• We keep accurate books, records, and accounts that correctly reflect the true nature of all transactions.
RED FLAGS TO REPORT TO LEGAL/COMPLIANCE
• Demands from a third party to receive its commission payment prior to winning a deal/contract
• Suggestions to direct GE business through a specific representative or partner due to a “special relationship”
• Requests to make a payment to a person who is not related to the transaction being discussed
• Commissions that seem too large in relation to the services provided
• Ambiguous “consulting fees” on invoices HELP CORNER
S&L Improper Payments Prevention Policy S&L Business Courtesies Procedure
12 | WIN WITH INTEGRITY / Improper Payments Prevention THE SPIRIT & THE LETTER YOUR ROLE
• Never offer, promise, make, or authorize a payment or the giving of anything of value to anyone in order to obtain an improper business advantage. Consult the GE Business Courtesies Procedure before providing a business courtesy to an external party.
• Follow your business due diligence procedures and require that any third party that (1) represents GE in promoting, marketing, and/or selling GE products to potential customers or (2) works with GE in the sale of GE products to potential customers, is carefully selected and complies with GE policy.
• Do not make facilitation payments to speed up routine administrative actions. The only exception is if it is necessary to protect the health or safety of you or another employee.
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