FixTheMusic is committed to conducting its business ethically and in compliance with all applicable laws and regulations, including the UK Foreign Corrupt Practices Act (FCPA), the UK Bribery Act (UKBA) and similar laws in other countries that prohibit improper payments to obtain a business advantage.
This document describes FixTheMusic’s Policy prohibiting bribery and other improper payments in the conduct of FixTheMusic business operations and employee responsibilities for ensuring implementation of the Policy. Questions about the Policy or its applicability to particular circumstances should be directed to our directors.
FixTheMusic strictly prohibits bribery or other improper payments in any of its business operations. This prohibition applies to all business activities, anywhere in the world, whether involving government officials or other commercial enterprises.
A bribe or other improper payment to secure a business advantage is never acceptable and can expose individuals and FixTheMusic to possible criminal prosecution, reputational harm or other serious consequences. This Policy applies to everyone at FixTheMusic, including all officers, employees and agents or other intermediaries acting on FixTheMusic’s behalf.
Each officer and employee of FixTheMusic has a personal responsibility and obligation to conduct FixTheMusic’s business activities ethically and in compliance with all applicable laws based on the countries wherein FixTheMusic does business. Failure to do so may result in disciplinary action, up to and including dismissal.
Improper payments prohibited by this policy include bribes, kickbacks, excessive gifts or entertainment, or any other payment made or offered to obtain an undue business advantage. These payments should not be confused with reasonable and limited expenditures for gifts, business entertainment and other legitimate activities directly related to the conduct of FixTheMusic’s business.
FixTheMusic has developed a comprehensive program for implementing this Policy, through appropriate guidance, training, investigation and oversight. Our directors have overall responsibility for the program, supported by the executive leadership of FixTheMusic.
Our directors are responsible for giving advice on the interpretation and application of this policy, supporting training and education, and responding to reported concerns. The prohibition on bribery and other improper payments applies to all business activities, but is particularly important when dealing with government officials.
The UK Foreign Corrupt Practices Act and similar laws in other countries strictly prohibit improper payments to gain a business advantage and impose severe penalties for violations.
The following summary is intended to provide personnel engaged in international activities a basic familiarity with applicable rules so that inadvertent violations can be avoided and potential issues recognized in time to be properly addressed.