Anti-bribery Policy

Colibri is committed to ethical business practices and to acting with integrity in all aspects of its business. Colibri's reputation for integrity is a vital business asset that depends upon the commitment of all Colibri officers, and employees everywhere to act in accordance with Colibri's Code of Conduct and all applicable laws and regulations. Colibri's reputation depends not only on its own conduct, but also on the conduct of those with whom it does business. It is Colibri's goal to ensure that all of its vendors, including suppliers of goods and raw materials, distributors, contractors, consultants, agents and other service providers (referred to hereafter as "Vendors") reflect the same high ethical standards as Colibri and demonstrate a commitment to compliance with all laws governing their activities, including laws prohibiting bribery or corruption. It is therefore required that Colibri's Vendors share this commitment to the U.S. Foreign Corrupt Practices Act ("FCPA") and anti-bribery compliance as set forth below:

  1. Our Vendors are aware that anti-bribery and anti-corruption laws around the world generally prohibit bribery of governmental officials and among private commercial parties, including the giving or receiving of bribes in connection with conducting business. More specifically, these laws prohibit people and organizations, or those acting on their behalf, from
    • paying or offering to pay money or anything of value, directly or indirectly, to (A) a government official to influence that official to secure an improper advantage or obtain or retain business, or (B) any private person or organization to induce any person to improperly perform a function or activity in connection with a business or organization, a person's employment, or a public function;
    • requesting, agreeing to receive, or accepting a financial or other advantage in exchange for improper performance of a function or activity in connection with a business or organization, a person's employment, or a public function.
  2. Our Vendors have not undertaken and will not undertake any action that would cause them or Colibri to be in violation of any anti-bribery laws, nor have they been accused of conduct that would violate any anti-bribery laws.
  3. Our Vendors understand that it is their responsibility to ensure that their employees and representatives understand and comply with this FCPA and Anti-Bribery Policy.
  4. Our Vendors understand that failure to adhere to this FCPA and Anti-Bribery Policy may cause Colibri to terminate the business relationship.