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Code of Business Conduct and Ethics - Crawford & Company

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Anti-Corruption<br />

Crawford & Company operates in many locations around<br />

the world, which means that we—<strong>and</strong> all of our subsidiaries<br />

throughout the world—must take special care to know <strong>and</strong><br />

follow all of the anti-corruption laws that apply to our work.<br />

Some of these laws include:<br />

u The U.S. Foreign Corrupt Practices Act (FCPA)<br />

u The UK Bribery Act<br />

u The Organisation for Economic Co-operation<br />

<strong>and</strong> Development Guidelines (OECD)<br />

u Similar local laws around the world<br />

These laws restrict us from bribing or attempting to bribe<br />

foreign government officials. We must also never work with<br />

third parties who divert funds for any corrupt practices, such<br />

as bribery, kickbacks, or improper payments. We are held<br />

responsible for the actions of our business partners, <strong>and</strong> seek<br />

to only work with partners who follow ethical st<strong>and</strong>ards<br />

like our own.<br />

A “bribe” may be:<br />

u Anything of value—including, but not limited to, money, gifts,<br />

favors, in-kind use of company resources, or entertainment<br />

u Viewed as an effort to influence an official’s actions or<br />

decisions<br />

u An attempt to obtain or retain business<br />

u Seen as an effort to acquire an improper advantage<br />

“Foreign government officials” may include:<br />

u Federal, state, or local government employees<br />

u Political c<strong>and</strong>idates<br />

u Political party officials<br />

u Members of royal families<br />

u Employees of businesses that are owned or<br />

otherwise controlled by a government<br />

u Employees of international organizations<br />

9 Acting Responsibly with Honest <strong>and</strong> Integrity<br />

Crawford & Company<br />

Code of Business Conduct <strong>and</strong> <strong>Ethics</strong>

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