FOREIGN CORRUPT PRACTICES ACT

The Foreign Corrupt Practices Act (FCPA), adopted in 1977, prohibits the
bribery of foreign government officials by U.S. persons and firms. The non-U.S.
subsidiaries of U.S. firms are also subject to this law. Liability results from an
actual payment, an offer or promise of payment, or the authorization of a
payment, offer, or promise for the purpose of obtaining or retaining business or
'any improper advantage' to which the company is not entitled. 'Grease
payments' to facilitate routine procedures, and the reimbursement of an official's
legitimate expenses associated with the execution of a contract, are allowable
under the FCPA.