This point should be obvious from the preceding discussion concerning interactions with government officials or employees, but it is so important as to be worth restating here. Payments of corporate, subsidiary or affiliate, or personal funds, or anything of value to a government official or employee of a political party or candidate for the purpose of obtaining or retaining business for Southwestern, or obtaining favorable governmental action, or to direct business to any other person are strictly prohibited. Indirect payments of this kind through a third person, such as a sales representative, distributor or consultant are also prohibited. Moreover, the Foreign Corrupt Practices Act prohibits such payments by Southwestern and its subsidiaries to government officials outside the United States even if the payment would be legal under the laws of the country where it is made. That Act also prohibits taking any action to assist or further any payments by third persons, even if not authorized, where there is “reason to know” that the payment will be used for any such purpose.
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