Company Policies
Company Policies
Anti-Bribery and Corruption Policy
Rauch International
Last updated: 2026
1. Purpose
Rauch International maintains zero tolerance for bribery, corruption, and improper influence in any form.
This policy establishes minimum standards of conduct for:
- Employees
- Directors and officers
- Subsidiaries and affiliates
- Operating companies
- Strategic partners
- Contractors
- Consultants
- Intermediaries
- Representatives
- Agents
No business objective justifies unethical behavior.
2. Scope
This policy applies to all activities conducted:
- In the United States and internationally
- With government entities and private companies
- Directly and through third parties
- Across all jurisdictions in which Rauch International operates or does business
This policy applies regardless of:
- Seniority
- Geography
- Role
- Contractual arrangement
3. Prohibited Conduct
Individuals associated with Rauch International must never directly or indirectly offer, provide, authorize, solicit, or receive:
- Bribes
- Kickbacks
- Corrupt payments
- Improper benefits
- Undeclared incentives
- Political inducements
- Personal favors
- Anything of value intended to influence decisions improperly
This includes:
- Cash or equivalents
- Gifts
- Hospitality
- Travel
- Employment offers
- Charitable or political donations made for influence
- Consulting arrangements used as a channel for payment
4. Government Officials
Special care must be taken when interacting with:
- Public officials
- Regulators
- Government agencies
- State-owned enterprises
- Political parties
- Candidates
- International organizations
Nothing of value may be offered for the purpose of:
- Obtaining or retaining business
- Securing improper advantage
- Influencing regulatory outcomes
5. Facilitation Payments
Facilitation payments are prohibited unless:
- Permitted by local law,
- Documented accurately, and
- Approved in writing by authorized management
No undocumented payment is permitted.
6. Gifts, Hospitality & Sponsorship
Permitted only if they are:
- Lawful
- Modest
- Properly recorded
- Not linked to improper influence
- Consistent with customary business practice
Anything that could appear to compromise independence is prohibited.
7. Third-Party Risk
Rauch International may be held responsible for actions taken by:
- Agents
- Distributors
- Intermediaries
- Consultants
- Business partners
Before engagement, appropriate diligence is required.
Third parties must:
- Agree contractually to ethical standards
- Comply with anti-corruption requirements
- Be monitored for compliance
8. Books & Records
All transactions must be:
- Recorded accurately
- Supported by documentation
- Transparent
- Traceable
False or misleading accounting is prohibited.
9. Reporting & Whistleblower Protection
Ethical concerns may be reported confidentially.
Reports may be submitted through the designated contact channel:
Rauch International prohibits retaliation of any kind against:
- Whistleblowers
- Cooperating individuals
- Good-faith reporters
Confidentiality is respected to the maximum extent possible.
10. Training & Awareness
Personnel subject to this policy may receive training on:
- Corruption risk
- Prohibited practices
- Reporting channels
- Local law expectations
Training may be provided periodically or as required.
11. Enforcement
Violations may result in:
- Termination
- Contract termination
- Legal action
- Loss of privileges
- Removal from partnership
- Civil or criminal penalties
Discipline is applied consistently.
12. Local Law Conflicts
Where local law conflicts with this policy, legal counsel shall determine direction.
In no case shall unlawful conduct be justified by:
- Local custom
- “Industry practice”
- Competitive pressure
- Business strategy
13. Policy Review
This policy may be updated periodically.
The latest version governs upon publication.
14. Acknowledgement
Certain roles may require acknowledgment of this policy as a condition of engagement.