BRIBERY AND CORRUPTION The Trial Parties must at all times act with integrity and honesty and comply with the highest ethical standards. The Trial Parties must not make, give, or offer any payment, gift or other benefit or advantage to any person for the purposes of: securing any improper advantage; or inducing the recipient or another person to do or omit to do any act in violation of their duties or responsibilities (or for the purposes of rewarding such conduct). This restriction applies at all times and in all contexts. For the avoidance of any doubt, it applies both to dealings with "public officials" and to dealings with employees and agents of commercial enterprises. Nevertheless, particular care must be exercised with dealings with public officials. The Trial Parties must not make, give or offer any payment, gift or other benefit or advantage for the purposes of influencing any act or decision of a public official (or inducing such official to use their influence with another person, entity or government instrumentality or to affect or influence any act or decision of such other person, entity or government instrumentality). The term "Public includes any person acting on behalf of any government Official" department, agency or instrumentality or any state-owned or controlled enterprise. By way of example, this includes health care professionals employed by a state- or local municipality-run hospital or clinic, and representatives of public international organizations. The Trial Parties must not make, give or offer any payment, gift or other benefit or advantage to any person whilst knowing or suspecting that all or a portion of such money, gift, benefit or advantage will be used, whether directly or indirectly, in breach of (B) or (C) above. The Trial Parties shall make and keep books, records, and accounts, which, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the Trial Parties, in accordance with Dutch law. The Trial Parties shall devise and maintain a system of internal accounting controls in accordance with Dutch law, sufficient to provide reasonable assurances that – transactions are executed in accordance with management’s general or specific authorization; transactions are recorded as necessary to permit preparation of financial statements in conformity with generally accepted accounting principles or any other criteria applicable to such statements, and to maintain accountability for assets;
BRIBERY AND CORRUPTION The Trial Parties must at all times act with integrity and honesty and comply with the highest ethical standards. The Trial Parties must not make, give, or offer any payment, gift or other benefit or advantage to any person for the purposes of: securing any improper advantage; or inducing the recipient or another person to do or omit to do any act in violation of their duties or responsibilities (or for the purposes of rewarding such conduct). This restriction applies at all times and in all contexts. For the avoidance of any doubt, it applies both to dealings with "public officials" and to dealings with employees and agents of commercial enterprises. Nevertheless, particular care must be exercised with dealings with public officials. The Trial Parties must not make, give or offer any payment, gift or other benefit or advantage for the purposes of influencing any act or decision of a public official (or inducing such official to use their influence with another person, entity or government instrumentality or to affect or influence any act or decision of such other person, entity or government instrumentality). The term "Public Official" includes any person acting on behalf of any government department, agency or instrumentality or any state-owned or controlled enterprise. By way of example, this includes health care professionals employed by a state- or local municipality-run hospital or clinic, and representatives of public international organizations. The Trial Parties must not make, give or offer any payment, gift or other benefit or advantage to any person whilst knowing or suspecting that all or a portion of such money, gift, benefit or advantage will be used, whether directly or indirectly, in breach of (B) or (C) above. The Trial Parties shall make and keep books, records, and accounts, which, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the Trial Parties, in accordance with Dutch law. The Trial Parties shall devise and maintain a system of internal accounting controls in accordance with Dutch law, sufficient to provide reasonable assurances that – transactions are executed in accordance with management’s general or specific authorization; transactions are recorded as necessary to permit preparation of financial statements in conformity with generally accepted accounting principles or any other criteria applicable to such statements, and to maintain accountability for assets;
Template-CTA-VIG-NFU-STZ-NKI-ACRON-2018-1.docx