Although ONE Gas conducts business on domestic soil, the company is still bound to laws governing foreign transactions. Many banks and insurance companies transact business through foreign branches, therefore, the Foreign Corrupt Practices Act of 1977 (FCPA) and the UK Bribery Act of 2010 apply to the company. Regardless of the place of incorporation, a business that employees a UK citizen or has offices in the UK falls under the UK Bribery Act, and any US companies dealing with that business are bound to the Act.
The combination of the relevant legal authorities prohibits employees, contractors and persons acting on behalf of the company from making payments or offers of payments of anything of value to company officials, foreign officials, political parties or candidates for foreign political office in order to secure business or to influence the official. Payments such as commissions, consulting fees, marketing expenses, service fees, customer intervention payments, etc., when made to a foreign official, are strictly prohibited by the law.
It is unacceptable for any employee, contractor or agent to make facilitation payments or “grease payments” or provide gifts and favors to a government official (foreign or domestic) or a third party company official for the purpose of gaining favor in a business transaction or to expedite routine and non-discretionary activities, such as obtaining a permit, visa or work order. The company will not tolerate this behavior. These anti-bribery provisions provide that companies and individuals can face severe criminal and financial penalties.