ww5 is committed to conducting its business activities in accordance with all applicable laws and regulations that prohibit bribery or corruption.  This prohibition against bribery and corruption is a cornerstone of ww5’s commitment to conducting business in an ethical manner, which is one of the Core Values reflected in ww5’s Code of Conduct.  In support of its commitment to integrity, ww5 expects all of its employees and business partners to abide by the anti-bribery and anti-corruption standards that ww5 has established as part of its ethics and compliance program.

Laws and Regulations

ww5 is committed to complying with all applicable anti-bribery and anti-corruption laws that apply to its business activities around the world, including but not limited to, the U.S. Foreign Corrupt Practices Act (“FCPA”), and U.K. Bribery Act and other anti-bribery and anti-corruption laws which may apply in relevant jurisdictions.

Code of Conduct

ww5’s Code of Conduct, which defines the ethical principles which guide our business activities, contains a specific prohibition on bribes, kickbacks and other transfers of value that are illegal or improper.  The Code of Conduct also contains a prohibition on using gifts or entertainment to improperly influence any business decision, and sets forth specific guidelines on the types of business courtesies which are consistent with ww5’s compliance expectations.

Anti-Bribery/Anti-Corruption Program Guide

ww5’s Anti-Bribery/Anti-Corruption Program Guide describes various components of the compliance program that ww5 has implemented in furtherance of its commitment to prohibiting bribery and corruption in its business activities.  This compliance program includes (without limitation) the anti-bribery/anti-corruption training and compliance resources that ww5 makes available to its employees, the due diligence procedures that are implemented with business partners or in connection with mergers and acquisitions, the approval requirements for business travel involving government officials, and the financial and accounting controls that have been established to maintain the adequacy of ww5’s books and records.

Business Partner Expectations

ww5 expects its business partners to abide by the same ethical standards with respect to bribery and corruption that apply to its employees.  In order to make its business partners aware of these standards, ww5 has developed anti-bribery and anti-corruption compliance language for its written contracts with business partners and also requires certain business partners to sign compliance certifications.  ww5’s business partners must commit to conducting business in an ethical and responsible manner.

Compliance Reporting and Monitoring

ww5 makes various mechanisms available for its employees and business partners to report any concerns they may have about ethical business practices (including practices which may be suspected of violating anti-bribery and anti-corruption laws).  These mechanisms include a confidential hotline for reporting concerns, which are reviewed by ww5’s legal and compliance team.  ww5 has a non-retaliation policy against anyone who makes a good faith report about an ethical concern.  To the extent that ww5 determines that any employee has violated its anti-bribery and anti-corruption policies and procedures, that employee is subject to disciplinary action (including termination of employment).  ww5 also conducts periodic audit and monitoring procedures to ensure that its business activities are being conducted in accordance with the anti-bribery and anti-corruption policies and procedures that it has established as part of its compliance program.