Corruption is contrary to our values of integrity, trust and respect, and it undermines our legacy and reputation as a trusted leader in outdoor recreation. We succeed based on our people, products and services, not on corrupt actions.
Our commitment to our values and to conducting our business with integrity means that we never provide or offer any form of bribe, kickback or other illegal payment.
Regardless of where we conduct business, we will always comply with applicable anti-corruption laws, including the United States Foreign Corrupt Practices Act as well as any applicable anti-corruption rules and laws in foreign jurisdictions.
These laws prohibit bribery of any foreign government official for the purpose of obtaining or keeping business, whether it occurs directly or indirectly through a third party, and they apply broadly to employees of foreign governments at any level, including;
We could be liable even if we did not know, but should have known, that a third party acting on our behalf was giving a government official an illegal payment.
Similarly, we must ensure that our relationships with consultants, sales representatives and other third parties from whom we receive services are always lawful and appropriately documented. In the course of doing business, any fees, discounts, commissions or other payments made should always be documented in writing and reflect the actual value of the service provided. Any such transaction should utilize common business practices and should never be paid for in cash.
If you are involved in foreign business transactions, you must fully understand and comply with the Foreign Corrupt Practices Act and other anti-corruption laws and regulations. Failure to adhere to these laws could result in significant penalties for Winnebago Industries, our officers, directors and employees, including disgorgement of profits, civil and criminal fines and imprisonment.
