10Bridgestone can be held responsible not only for bribes offered, paid or received by employees, but also when Intermediaries do so. Use great care when hiring and working with Intermediaries. Like Bridgestone employees, Intermediaries are prohibited from offering, providing, receiving or accepting anything of value to or from anyone, including a Government Official, to obtain or retain business or for any other improper advantage.To help prevent bribery, you must always be aware of the activities conducted by Intermediaries on Bridgestone’s behalf and stay alert to warning signs that may indicate potential misconduct. To reduce the risk of bribes by an Intermediary, you must act carefully when selecting and evaluating Intermediaries and identify in advance any potential anti-bribery concerns that may arise from the proposed relationship. This “anti-bribery due diligence” is a critical component of our anti-bribery compliance program.Bridgestone Global Anti-Bribery PolicyBridgestone takes a risk-based approach to conducting anti- bribery due diligence. While the amount of time and effort required to complete the process will depend on various factors, the anti-bribery due diligence process will typically include the following:• Assessing the business justification, services and compensation structure for the proposed engagement;• Collecting and evaluating information about the Intermediary and its ownership and management, including business background, reputation, qualifications and financial information;• Assessing any relationships with Government Officials;• Following up on warning signs or irregularities; and• Obtaining any required approvals in advance of an engagement.Throughout the anti-bribery due diligence process and also during contract performance, it is important to look out for “red flags” that may indicate that further investigation is warranted when selecting or working with an Intermediary.Dealings With Third PartiesDue Diligence
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