The present Policy was established to support this commitment by ensuring compliance with the principles and objectives of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions of the Organization for Economic Cooperation and Development (the OECD Convention) and of secondary legislation, including the Austrian act amending the criminal law on corruption (Korruptionsstrafrechtsänderungsgesetz, KorrStrÄG) 2012 Fed. Law Gaz. No. I 61, the U.S. Foreign Corrupt Practices Act (FCPA) and the United Kingdom’s Bribery Act 2010. These laws and other national laws from around the world prohibit or restrict the direct or indirect provision of payments or valuables to government officials, customers’ agents, or political parties, and require strict controls over the disposition and accounting records of business assets. 

This Policy applies to all members of the management, executives and employees of GW, its subsidiaries and affiliates that are directly controlled by GW, and any other legal entity or company acting on behalf of GW. GW will seek to implement the present or any equivalent policy in companies in which GW has ownership interests, but does not control operations. In the event that certain circumstances arise, GW has provided for measures that are more restrictive than those provided for by law because of GW’s commitment to ethical corporate values and its business reputation in the world. Procedures to ensure compliance with the Anticorruption Policy are included in the Third Party Management Program.