Rauch Construction often enters into business relationships with other persons and companies internationally, where Third Parties and Partners may interact with Foreign Officials on behalf of Rauch. Rauch policy governs the manner in which it will enter into and manage these business relationships.
The term “International Business Relationships” includes the following:
- Any commercial agent, sales representative, sponsor, consultant or any other party to assist Rauch in obtaining or promoting business and/or performing advocacy with government officials on behalf of Rauch;
- Any party who assists Rauch with obtaining a regulatory approval from a government entity such as customs brokers, visa expediters, freight forwarders and importers/exporters; or any party who assists with the resolution of a dispute, claim or debt involving a government entity; or any party who interacts on behalf of Rauch with government officials or employees who have some discretionary authority over a matter that could impact Rauch’s existing or potential business. This could include contractors, subcontractors, real estate or property agents and scientific or technical consultants;
- Any partner in a project-specific or permanent joint venture, equity investment, consortium, partnership, teaming arrangement, or strategic alliance with Rauch;
- Any direct business transaction with a Foreign Official, Close Relative of a Foreign Official such as spouse, parent, in-laws, grandparents, children, siblings, first cousins, or an entity in which a Foreign Official or his/her close relative holds a financial or beneficial interest.
While International Business Relationships are useful in the conduct of Rauch’s business, they must be adequately subject to Rauch’s systems of control to protect Rauch’s assets against unauthorized use. Also, Rauch may be held accountable for actions taken by others on its behalf. Thus, Rauch policy requires that selection of other parties with whom Rauch will join in International Business Relationships must be subject to review and approval and conform to Rauch’s Anti-Corruption Policies.