Fedders Corporation
Code of Business Conduct and Ethics
INTERACTING
WITH GOVERNMENT
Prohibition on Gifts to Government Officials and Employees
The various branches and levels of government have different
laws restricting gifts, including meals, entertainment,
transportation and lodging, that may be provided to government
officials and government employees. You are prohibited from
providing gifts, meals or anything of value to government
officials or employees or members of their families without
prior written approval from the Vice President & General
Counsel. See Corporate Policy 9.1-"Corporate Payments."
Political Contributions and Activities
Laws of certain jurisdictions prohibit the use of Company
funds, assets, services, or facilities on behalf of a political
party or candidate. Payments of corporate funds to any political
party, candidate or campaign may be made only if permitted
under applicable law and approved in writing and in advance
by the Vice President & General Counsel. See Corporate
Policy 9.1-"Corporate Payments."
Your work time may be considered the equivalent of a contribution
by the Company. Therefore, you will not be paid by the Company
for any time spent running for public office, serving as
an elected official, or campaigning for a political candidate.
The Company will not compensate or reimburse you, in any
form, for a political contribution that you intend to make
or have made.
Lobbying Activities
Laws of some jurisdictions require registration and reporting
by anyone who engages in a lobbying activity. Generally,
lobbying includes: (1) communicating with any member or
employee of a legislative branch of government for the purpose
of influencing legislation; (2) communicating with certain
government officials for the purpose of influencing government
action; or (3) engaging in research or other activities
to support or prepare for such communication.
So that the Company may comply with lobbying laws, you must
notify the Legal Department before engaging in any activity
on behalf of the Company that might be considered "lobbying"
as described above.
Bribery of Foreign Officials
Company policy, the U.S. Foreign Corrupt Practices Act (the
"FCPA"), and the laws of many other countries
prohibit the Company and its officers, employees and agents
from giving or offering to give money or anything of value
to a foreign official, a foreign political party, a party
official or a candidate for political office in order to
influence official acts or decisions of that person or entity,
to obtain or retain business, or to secure any improper
advantage. A foreign official is an officer or employee
of a government or any department, agency, or instrumentality
thereof, or of certain international agencies, such as the
World Bank or the United Nations, or any person acting in
an official capacity on behalf of one of those entities.
Officials of government-owned corporations are considered
to be foreign officials.
Payments need not be in cash to be illegal. The FCPA prohibits
giving or offering to give "anything of value."
Over the years, many non-cash items have been the basis
of bribery prosecutions, including travel expenses, golf
outings, automobiles, and loans with favorable interest
rates or repayment terms. Indirect payments made through
agents, contractors, or other third parties are also prohibited.
Employees may not avoid liability by "turning a blind
eye" when circumstances indicate a potential violation
of the FCPA.
The Company requires strict adherence to Corporate Policy
1.2-"Employee Business Conduct" and Corporate
Policy 9.1-"Corporate Payments."
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