Summary of Criteria for Interactions with Non-US Officials

All gifts, entertainment, and hosting of any non-U.S. official and all facilitating payments to any non-U.S. official should meet the following basic criteria as well as any specific criteria in this Summary:

  • Comply with local customs and laws, as locally interpreted and administered;
  • Comply with any other applicable laws, such as the FCPA and the U.K. Law on Bribery and Corruption;
  • Be properly endorsed, approved, and reported in accordance with the LXGlobal Guidelines for Interactions with Non-U.S. Officials;
  • Be accurately and completely recorded in LXGlobal's books and records; and
  • Be open and transparent.