Bribery:

SnackCo of America’s personnel are strictly prohibited from offering, paying, promising, or authorizing any payment or other item of value to any person directly or indirectly, through or to a third party, for the purpose of: Causing the person to act or fail to act in violation of legal duty, Causing the person to abuse or misuse their position, Securing an improper advantage, contract or concession.

Improper Payment Activity:

To promote compliance with anti-corruption laws in the United States and any other applicable jurisdictions, no SnackCo personnel shall undertake any Improper Payment Activity with respect to a foreign official, a domestic official, or a person doing business in the private sector.

In addition, SnackCo’s books and records must correctly record both the amount and a written transaction.

Gifts, Hospitality and Expenses:

SnackCo associates may not offer to or accept from third parties: gifts, hospitality, rewards, benefits, or other incentives that could affect either party’s impartiality, influence a business decision, or lead to the improper performance of an official duty.

Personal Conflicts of Interest:

SnackCo associates must avoid situations or transactions in which their personal interests could conflict or might be seen to be in conflict with the interests of the company.

This includes acting on any client information gained through their employment with the company for personal gain, passing such information to a third party, or acting in any way that could be construed as insider trading.

Associates must disclose any personal conflict of interest or perceived conflict to their manager.