16Q: I understand that “facilitating payments” (small payments made to Government Officials to expedite routine transactions) are prohibited by company policy. Are officially authorized fees, such as expediting fees for passport renewals or visa applications, considered “facilitating payments”?Q: I know that bribery is prohibited, but what if a Government Official (such as a police officer or immigration officer) threatens to detain or harm me unless I give him or her a nominal cash payment?Q: I know it is against the law to make payments to Government Officials, but everybody tells me that it is the only way to get things done in this country. Can I get around this by hiring an agent who will pay the officials a commission?A: Expediting payments made to a government agency (not to an individual) that are officially authorized (such as a rush fee listed on a government agency schedule to expedite the processing of passport renewals or visa applications) and are backed up with an official government receipt are not “facilitating payments” and, accordingly, are generally allowed. Contact the Law Department if you are unsure whether an expediting payment is appropriate and legal.A: Bridgestone recognizes that, in extremely rare situations, an employee’s health or safety could be at risk if he or she fails to comply with such a request. If you feel your health or safety is in imminent danger and, in your judgment, the best way to protect yourself is to make the payment, company policy does not prohibit you from making such a payment. These types of payments are not bribes. As soon as you reach a place of safety, immediately report the payment to your manager, the Law Department, and, where applicable, the Security Department. The payment must also be properly reported and documented in the company's books and records.Bridgestone Global Anti-Bribery PolicyA: No. It is against the law to pay bribes to Government Officials regardless of whether the payment is made directly or indirectly through a third party. The consequences of making such payments could be severe for both you and the company. You cannot get around your or the company's legal responsibilities by hiring agents to do what you are not permitted to do. Therefore, when considering hiring an agent, appropriate due diligence must be conducted to carefully assess the rationale for the hiring, whether the proposed fees are appropriate for the services to be provided, and the background, reputation and qualifications of the agent. Consult with the Law Department to learn more about Bridgestone’s due diligence process.Q & A
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