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Your Distributor is
Peggy Mills
Remove
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$ Retail Promo $ Monthly Promo
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Orders in your market are limited to $ per month. If you have questions, please refer to our Global Customer Program Terms & Conditions.

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Compliance Corner – June 2019 Article

Foreign Corrupt Practices Act (FCPA)

“Congress enacted the FCPA in 1977 after revelations of widespread global corruption in the wake of the Watergate political scandal. SEC discovered that more than 400 U.S. companies had paid hundreds of millions of dollars in bribes to foreign government officials to secure business overseas.

“The Act was intended to halt those corrupt practices, create a level playing field for honest businesses, and restore public confidence in the integrity of the marketplace.”

A Resource Guide to the U.S. Foreign Corrupt Practices Act 

 

Through the Legal and Compliance Departments, LifeVantage Corporation trains each and every one of its employees each year on compliance with the FCPA. The company adheres to the highest standards of business conduct and we expect our employees and third parties we do business with to comply with these same high standards of business ethics. The purpose of this brief article is to educate our independent LifeVantage distributors about basic FCPA compliance and to help you understand why compliance is critical to LifeVantage’s and your success in building an independent LifeVantage business.

Who is covered by the FCPA? The Act defines covered U.S. “Persons” as: 

  • S. Citizens, Nationals, or residents of U.S.
  • Entities based in U.S. or issuers of U.S. Securities
  • S. investors in a foreign entity
  • Officers, directors, employees, agents, stockholders of U.S. Entities

In 2012, the Department of Justice (DOJ) and the Securities & Exchange Commission (SEC) made it clear through three enforcement actions that independent distributors are covered under the Act the same as any other agent or representative. Although distributors are not agents as that term is typically defined for legal purposes, the DOJ and SEC treat distributors for FCPA compliance the same as sales agents, resellers and any other entity or individual that sells a U.S. company’s products outside the United States. This is why it’s important for our LifeVantage distributors to understand FCPA rules.

Certain non-U.S. “Persons” also may be covered by the FCPA. For example, non-U.S. subsidiaries of U.S. parent, non-U.S. agents (or distributors) acting on behalf of U.S. companies, and non-U.S. persons acting while in U.S. territory.

The FCPA’s Anti-Bribery Provisions generally prohibit the promise, authorization, payment, or offer of money or anything of value, “corruptly,” directly or indirectly, to any foreign official for the purpose of influencing an official or securing any improper advantage, in order to obtain or retain business. Violations of the FCPA can result in criminal penalties, sanctions, and other remedies, including fines, disgorgement of profits, and/or imprisonment.

What does this mean for our LifeVantage distributors? When operating your LifeVantage distributorship, DO NOT:

  • make any payment (or offer or promise to make any payment or offer anything of value) with the intent to influence the recipient to misuse his/her position to secure an improper advantage for LifeVantage or your independent LifeVantage business. This includes offering or making charitable donations or providing entertainment.
  • make a payment or an offer or promise of payment or anything of value to an individual who is a foreign government official or a relative of a government official.
  • make any payment to a non-governmental commercial enterprise in which a foreign-government official has any financial interest.

We hope that you find value in this brief overview of the FCPA rules. If at any time you should have questions concerning the FCPA and compliance with the Act, please contact the Compliance Department at compliance@lifevantage.com or the Legal Department at 801-432-9148.

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