DynCorp International Corporate Commitment to Comply with
Anti-Corruption and U.S. Foreign Corrupt Practices Act
DynCorp operates in many countries where corruption is endemic and it is our policy to comply with the spirit as well as the letter of the law related to anti-corruption. DynCorp International and its directors, officers, and employees commit to conducting all of our operations in compliance with the provisions of the Foreign Corrupt Practices Act (FCPA) and the anti-bribery laws of those countries in which we work and with applicable international conventions.
Under the direction of the Chief Administrative Officer and Chief Legal Officer, DI has designated empowered senior officers to ensure that the company complies with all international trade and anticorruption compliance laws and regulations.
In compliance with our policy as well as U.S. and international law and regulations, we commit to performing due diligence investigations to confirm that parties with whom we do business are legitimate and trustworthy enterprises that will comply with the FCPA and anti-corruption policies, laws and regulations. Further, all suppliers that DI engages internationally are required to certify that they comply with the FCPA and are required to re-certify annually. Due diligence investigations are conducted before entering into any agreement and at later stages if red flags are raised.
To ensure that employees who may be exposed to corrupt activities are aware of the risks of corruption and understand their company and legal obligations, potentially exposed employees are required to complete FCPA training courses at the time of hire and at least once a year thereafter. In that training, employees will learn their responsibility for understanding the FCPA and host country anti-bribery laws, for complying with these laws, and for reporting immediately any suspicion of violations. Employees learn that there is strict prohibition/controls on the use of any foreign agents without Legal Department review and written approval. Following training, every employee will certify that they have been instructed in, understand and will comply with anti-corruption policy, laws and regulations. Managers are responsible for assuring such courses are completed and the HR Department maintains records of course completion.