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Viacom strives to maintain throughout its global operations a work environment that reflects  the  highest  standards  of  business  ethics  and  workplace  behavior,  and  is committed to legal compliance and ethical business practices in all of its operations worldwide.1    In furtherance of these standards, Viacom expects all of its suppliers to comply with all applicable laws and regulations in the places in which they do business, and  to  maintain  the highest  degree of ethics  in  every aspect  of  their  business  with Viacom.  Viacom is firm in its resolve to do business only with those suppliers who share in its commitment to integrity.


All of Viacoms suppliers should be familiar with Viacoms Business Practices Statement (“BPS”), formerly known as the Business Conduct Statement.  The BPS can be found at Hard copies are also available upon request to Viacoms Compliance Officers (the BPS contains instructions on the various means of communicating with Viacoms Compliance Officers).  All suppliers must maintain accurate financial reporting systems and records relating to their dealings with Viacom, and familiarize themselves with all of the BPS policies.


They should be particularly aware that Viacom expects strict  COMPLIANCE with all applicable laws, regulations and standards regarding:


     Anti-corruption and anti-bribery, including for example, the United States Foreign Corrupt Practices Act and the Organization for Economic Cooperation and Development Convention on Combating Bribery of Foreign Public Officials in International Business Transactions;


     Political contributions and payments;


     Trade embargos and boycotts (particularly United States anti-boycott laws);


     Government contracting;


     Imports and exports generally, and on technology in particular; and


     Fair  and  ethical  employment  practices  including  those  relating  to  improper discrimination, child and forced labor; wages; hours; overtime and benefits; and health, safety and the environment.


Viacom policy PROHIBITS all of the following conduct:


     The offering or giving of direct or indirect, improper payments, gifts or other things of value, to any domestic or foreign government official or employee, as well as their representatives, agents or family members;


     The offering or giving of money, discounts, entertainment, meals, transportation, gifts or other favors or personal benefits to Viacom employees, other than as appropriate and necessary to fulfill the supplier’s contractual obligations;


     Anti-competitive business practices and non-adherence to applicable local and international antitrust laws;


     The  incorporation  into  any  products  we  may  manufacture  or  contract  to manufacture of “conflict minerals,” which are minerals smelted into tin, tantalum, tungsten and gold sourced from the Democratic Republic of Congo or adjoining countries, without prior written authorization;


     Use of Viacoms name, assets (including, without limitation, intellectual property such as any Viacom trademarks or logos), facilities or services without prior written authorization or for any improper purpose;


     Disclosure  of  confidential  and  proprietary  information  to  any  third  party

(including, without limitation, the press) without prior written authorization;


     Improper discrimination in the work environment; and


     Acts  of  sexual,  physical,  mental  or  any  other  form  of  harassment,  abuse  or improper behavior in the workplace and in any work-related setting outside the workplace, such as during business trips, business meetings and business-related social events.


Viacom cooperates with law enforcement authorities in the proper execution of their responsibilities.  Viacom also collaborates with its suppliers on educational programs and other efforts to enhance legal compliance on the part of their industries.


If it is found that a supplier has committed one or more violations of this policy, Viacom will take appropriate action to the extent enforceable under local law.  Such action may range from working with the supplier to ensure that steps are taken to address the violations and prevent their reoccurrence, to canceling the affected contract, terminating the relationship with the supplier, making disclosures to law enforcement or regulatory authorities  and  commencing  legal  action  against  the  supplier  or  other  actions  as warranted.


For any questions regarding Viacoms Supplier Compliance Policy, please contact a Viacom Compliance Officer.



1 Viacom means Viacom Inc. and all its businesses, divisions and subsidiaries, including, without limitation: Viacom Media Networks; BET Networks; and Paramount Pictures. For a full list, please contact Viacom.



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