Anti-Bribery & Corruption Policy

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 Book-A-Load Logistics, LLC, and its Affiliate Companies, and/or Independent Contractors will not tolerate bribery and corruption of any kind. We will not seek to influence others, either directly or indirectly, by offering, paying, or receiving bribes or kickbacks, or by any other means that is considered unethical, illegal, or harmful to our Reputation of Honesty and Integrity. Owners, Employees and Representatives of the company and affiliate companies are expected to decline any opportunity which would place our Ethical Principles and Reputation at risk. While certain laws apply only to bribes to government officials (domestic and foreign); this policy applies to non-government business partners as well. 

  Bribery and Corruption are not only against our Company’s Core Values; they are illegal and can expose both the Employee and the Company to fines and penalties, including imprisonment and Reputational damage.

 LAST UPDATED 12/09/2022 

People want to work with companies they can trust. Book-A-Load Logistics, LLC has built a strong reputation for being an ethical, trustworthy company. 

Bribery is offering, giving, or receiving anything of value with the intention of inducing a person to act or to reward a person for having acted. This includes kickbacks—giving a payment to someone who helps facilitate a transaction. It’s important to understand that a corrupt act has occurred even if:

• A bribe does not succeed.
• A person authorizes or provides direction for a bribe, but no bribe is ultimately offered or paid.

“Anything of value” includes, but is not limited to:

• Cash, cash equivalents (such as gift certificates/cards), stock, personal  property, and assumption or forgiveness of a debt.
• Gifts,  meals, entertainment, and travel—any corporate travel, gifts,      entertainment, and meals must be proportionate to the occasion and comply with the gift & entertainment policy/standards applicable to your  location.
• Political  contributions.
• Charitable  contributions—if made to a charity at the direct request of a government      official or private business partner, it could be considered an indirect bribe made to obtain or retain business or to secure other improper  business advantage.
• Job offers or internship awards—offers to government officials (or their relatives) can present a risk of violating anti-bribery or anticorruption  laws and regulations. Compliance must be consulted prior to making such      offers.

Corruption is dishonest or fraudulent conduct by those in power, typically involving bribery.

The U.S. Foreign Corrupt Practices Act of 1977 (FCPA) is a United States Federal Law that prohibits U.S. citizens and entities from bribing foreign government officials to benefit their business interests. The FCPA enforced by the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC), which apply criminal and civil penalties, respectively. 

The FCPA was enacted for the purpose of making it unlawful for certain classes of persons and entities to make payments to foreign government officials to assist in obtaining or retaining business.

The Anti-Bribery and Corruption Policy establishes principles that must govern our conduct to 1.) conform to the U.S. Foreign Corrupt Practices Act (FCPA) and similar anti-corruption laws worldwide and 2.) more broadly, reinforce our intention and obligation to act honestly and ethically in all our business dealings.

This policy applies to all employees, affiliates, and partners in wholly and majority-owned entities of Book-A-Load Logistics, LLC.

The Majority Owners of Book-A-Load Logistics, LLC are the final Authority for this policy.

The Majority Owners oversees the assessment of bribery and corruption risks across the company, as well as, evaluating controls, consulting, and reporting all anti-bribery and corruption (AB&C) risks.

Companies cannot avoid liability by using a third party to give or receive a bribe. A third party includes, but is not limited to consultants, agents, representatives, subcontractors, and subadvisors.

We must clearly convey to third parties representing the company that we expect them to comply with our Anti-bribery and corruption policy. In some jurisdictions, the company can be convicted of a criminal offense if it fails to prevent bribery carried out on its behalf by a third party even if no one in the company had actual knowledge of the bribe.

Whenever the company seeks to engage a third party in which the third party may interact with a government official for or on behalf of the company, the following guidelines apply:

1. Due diligence should be performed to ensure that the third party is a bona fide and legitimate entity; is qualified to perform services for which it      will be retained; and maintains standards consistent with the legal, regulatory, ethical, and reputational standards of the company.
2. Agreements with third parties must be in writing and should contain provisions  related to the following, based on corruption risk present in the third-party relationship:
   • A  representation that the third party will remain in compliance with all       relevant anti-corruption laws, including the FCPA.
   • A  provision that requires the third party to respond to reasonable requests for information from the company regarding the work performed under the       agreement and related expenditures by the third party.

Laws and Regulations are strict when dealing with Government Officials. Reasonable corporate hospitality that is acceptable with other Business Associates might not be allowable when Government Officials are involved.

Approval must be attained from our Compliance Director/Legal Contact before such expenses are incurred. 

A Government Official is any:

• individual elected or appointed to a governmental entity,
• official or  employee of a government,
• official or  employee of a company wholly or partially controlled by a government (such      as state-owned companies),
• candidate  for political office,
• political  party or official of a political party, or
• person acting  in an official capacity for any of the above regardless of rank or position.

The definition of what could constitute a bribe to a government official is broad and can occur even when the benefit being offered is small, such as gifts, entertainment, and even business meals.

Some laws allow expenses which relate to reasonable and bona fide travel, accommodation, and meal expenses in connection with a contract between the company and the third party, or the demonstration of company capabilities relating to proposed business with the third party.

“Facilitation or grease payments” are payments that facilitate a normal governmental function, such as to expedite processing paperwork. While these types of payments may be accepted as “a cost of doing business” in some cultures, they are illegal and counter to our values. They are not allowed under the U.K. Bribery Act and they are prohibited by this policy.

Employees and Representatives should seek clarification on any questions or concerns regarding activities under consideration or the interpretation of any law. If you are offered a bribe from a person or entity doing business with or seeking to do business with the company, report it immediately to your business area’s compliance director/legal contact. If you are offered something of value and are uncertain whether you’re allowed to accept it, refer to the gift & entertainment policy and standards applicable to your location, or check with your leader or your business area’s compliance director/legal contact. Violations can be reported anonymously by using the Ethics Hotline or online reporting form (available on the intranet or internet). Our whistleblower policy protects employees who report concerns in good faith.

The anti-bribery provisions of the FCPA prohibit the willful use of the mails or any means of instrumentality of interstate commerce corruptly in furtherance of any offer, payment, promise to pay, or authorization of the payment of money or anything of value to any person, while knowing that all or a portion of such money or thing of value will be offered, given or promised, directly or indirectly, to a foreign official to influence the foreign official in his or her official capacity, induce the foreign official to do or omit to do an act in violation of his or her lawful duty, or to secure any improper advantage in order to assist in obtaining or retaining business for or with, or directing business to, any person.

Since 1977, the anti-bribery provisions of the FCPA have applied to all U.S. persons and certain foreign issuers of securities. With the enactment of certain amendments in 1998, the anti-bribery provisions of the FCPA now also apply to foreign firms and persons who cause, directly or through agents, an act in furtherance of such a corrupt payment to take place within the territory of the United States.

The FCPA also requires companies whose securities are listed in the United States to meet its accounting provisions. See 15 U.S.C. § 78m. These accounting provisions, which were designed to operate in tandem with the anti-bribery provisions of the FCPA, require corporations covered by the provisions to (a) make and keep books and records that accurately and fairly reflect the transactions of the corporation and (b) devise and maintain an adequate system of internal accounting controls.

For particular FCPA compliance questions relating to specific conduct, you should seek the advice of counsel as well as consider using the Department of Justice's FCPA Opinion Procedure, found on The United States Department of Justice website: https://www.justice.gov/criminal-fraud/foreign-corrupt-practices-act

By Mail
Correspondence relating to the Foreign Corrupt Practices Act (FCPA) may be sent to:

Fraud Section, Criminal Division
U.S. Department of Justice
ATTN: Chief, FCPA Unit
950 Constitution Ave., NW
Washington, DC 20530

By E-Mail
Report a FCPA Violation via Email to FCPA.Fraud@usdoj.gov.

ANTI-CORRUPTION SITES: https://www.justice.gov/criminal-fraud/anti-corruption-sites