First Global Capital Corporation

The Law
The Foreign Corrupt Practices Act (FCPA) makes it unlawful for any U.S. citizen or company to offer, pay, transfer, or promise to pay or transfer, or to authorize a payment, transfer, or promise of money or anything of value to any foreign appointed or elected official, foreign political party, or candidate for a foreign political office in order to influence an action by that person to cause the U.S. citizen or company to obtain or retain business. Penalties for non-compliance can include incarceration and significant fines.

FGCC Statement of Position
Corruption is a significant impediment to economic and political development, particularly in those countries with emerging markets. FGCC supports the goal behind the Foreign Corrupt Practices Act, which is to foster and encourage greater transparency and to reduce corruption by prohibiting U.S. entities from engaging in corrupt practices in their foreign activities. In addition, FGCC upholds the terms of the OECD Convention on Combating Bribery of Foreign Officials in International Business Transactions (1997), the Inter-American Convention Against Corruption (1996), and the Rules of Conduct to Combat Extortion and Bribery of the International Chamber of Commerce (1996).

FGCC Compliance Procedures
In order to assure FGCC's compliance with the FCPA, the company has established the following procedures:

1. Each employee and partner is made aware of the FCPA, its provisions, and the need to fully comply by virtue of being provided the following information in writing.

2. Prior to making any payments greater than $1,000 to a foreign individual or political party for other than purchases of routine goods or services, the company requires that the following process be followed. The person generating the request for payment shall bring the circumstances surrounding the request to the corporate officer in charge of compliance. The compliance officer will then make a determination as to the legality of the proposed payment and inform both the requesting individual and the bookkeeper as to the validity of such a payment.

3. The company's books will be audited at the end of each fiscal year by a reputable accounting firm.

If you have any questions regarding the FCPA and FGCC compliance, please call us at 310-893-6400 or email us at info@fgcapital.com.