Westinghouse has ZERO tolerance policy for all forms of bribery or corruption. This means that no one at Westinghouse or any company affiliated with Westinghouse may offer, give, or accept anything of value in exchange for a business advantage. Things of value can be more than just money. They can be lavish gifts or hospitality, offers of employment, small “grease” payments, charitable contributions, political donations, or payments made through third parties. Westinghouse has policies that address these issues for your further reference and are available at the links discussed below. We know that bribery laws can be tricky, so you should review the Westinghouse anti-corruption policy (BMS-LGL-11) for more information on these topics and ask questions if you have a concern need additional information.
Act Responsibly when Giving or Receiving Gifts, Hospitalities, and Travel
Providing or accepting modest gifts, hospitalities, and travel is part of doing business globally. However, if done lavishly, it can create the appearance that business decisions are made unfairly and could be viewed as bribery. If you are giving or receiving gifts, hospitalities, or travel, it is your responsibility to ensure that you comply with the Westinghouse Global Policy on Gifts, Hospitality and Travel (BMS-LGL-22). Cash or cash equivalents (such as gift cards) are never permitted.
Ensure Appropriateness of Charitable Contributions & Political Contributions
Employees are encouraged to be active in their communities, including by making charitable contributions at their own personal choice, by volunteering their time, or personally supporting political candidates.
In some instances, however, charitable contributions, political donations, other similar contributions (such as contributions to social welfare organizations or other not-for-profit organizations) may present a risk of corruption, particularly in certain countries. When participating in Westinghouse sponsored charitable programs, employees are not authorized to make charitable contributions on behalf of the company without prior approval under the policy (BMS-COM-05). When participating in political activities, employees must follow the guidance described in the policy (BMS-LGL-101). For activities with the U.S. Government, employees should consult the Westinghouse Government and International Affairs office before engaging in interactions.
Know Your Business Partners
Westinghouse often engages third parties to act on our behalf or to act as our partner. In most cases, Westinghouse is responsible for the actions of those third parties taken on our behalf or for our benefit. To ensure Westinghouse is protected, employees should review and engage compliance for assistance with complying with BMS-LGL-66 (Intermediaries) and BMS-LGL-100 (Business Partners).
You can support the visits of public officials and employees of government-owned and controlled entities, but only if fully approved in advance by the Legal and Global Compliance organizations. It is permissible to promote and demonstrate our products and technology to government employees who are decisionmakers or potential partners, but you must not try to influence them by offering personal benefits. Meals, hospitalities, and entertainment must be in compliance with our corporate policies, applicable laws, and government, customer, or supplier policies — in particular with respect to public officials.
You must work with the Global Compliance organization to ensure that the contribution is provided in accordance with all applicable laws, including anti-corruption law and Westinghouse policy. We have to be extra careful when a request for a charitable contribution comes directly from a public official and must scrutinize these contributions closely because in some instances, charitable organizations have been used as a means of corruption.
No, our policy monitors not only direct contributions of Company money, but also contributions of Company time or money spent in support of candidates or political parties, such as the purchase of tickets to political fundraising events or the furnishing of goods, services, equipment, or other things of value to candidates, political parties, or committees. These contributions may be allowable but require prior approval from the Global Compliance organization and the Westinghouse Government and International Affairs office.
A bribe is offering, giving, or promising to give anything of value with the intent to improperly influence business decisions and create/or obtain an unfair business advantage. Given the circumstances, intent may be implied, even if not expressed. Bribes may include: cash, cash equivalents, and/or loans; lavish gifts, hospitality, travel, and entertainment; offers of employment; other favors, either business-related or personal; and charitable or political contributions.
The wrongful use of influence in a business dealing to procure a benefit for the actor or another person, contrary to the duty and/or the rights of others. Corruption occurs in various forms, including bribery, kickbacks, illegal gratuities, economic extortion, collusion, and conflicts of interest.
Government is defined to include all levels and subdivisions of government (i.e., local, municipal, provincial, state, regional, or national, and the administrative, legislative, judicial, and executive branches); government-owned enterprises; and quasigovernmental organizations that are wholly or partially supported by government funds. Public official is any elected or appointed government official or employee at all levels of government (local, state, or national) or branch (legislative, executive, or judicial); anyone acting on behalf of a public official, agency, instrumentality, or enterprise that performs a government function; any employee or other person acting for or on behalf of any entity that is controlled by more than 50% by the government; any government-owned or controlled company; any political party, a political candidate, or anyone acting for or on behalf of a political party; any candidate for public office; or any employee or person acting for or on behalf of a public international organization.
Any third party that represents the Company, acts on its behalf, or acts jointly with the Company for the purposes of obtaining, retaining, or directing business as well as distributing or reselling the Company’s products and/or services, including commissioned sales agents, distributors, sales representatives, consultants, lobbyists, transportation or logistics providers, customs clearing agents, brokers, joint venture partners, and any non-Company third parties operating under a power of attorney granted by the Company.
