Foreign Corrupt Practices Act Compliance Policy
Dear Fellow Employees,
Willbros Group, Inc. expects all of its employees and representatives to conduct its business in accordance with the highest standards of ethical behavior and honesty. As a result of certain inappropriate employee conduct described in recent public announcements by the Company, the Board of Directors believes it is necessary to reiterate in the plainest possible terms the importance of the Company’s requirements regarding the conduct of its employees and representatives.
All employees of the Company and its subsidiaries are expected to read the attached Policy and to strictly comply with every aspect of its requirements. In addition, the Company is issuing a Foreign Corrupt Practices Act Compliance Manual detailing specific procedures to be followed in each employee’s day-to-day activities in order to ensure complete compliance with this Policy. The Manual also provides procedures for obtaining guidance in situations where questions arise regarding the proper course of action or where the applicability of the Policy to particular circumstances is not clear.
There are no exceptions to the attached Policy or any legitimate excuses for non-compliance with its terms. Any failure by any employee or representative of the Company or its subsidiaries to comply with the requirements of the attached Policy will be dealt with severely. If any employee observes conduct which he or she believes is a violation of the Policy, such conduct should be reported immediately using the procedures specified in Section of 3.6 the Company's Foreign Corrupt Practices Act Compliance Manual.
I trust you appreciate that the conduct required by the attached Policy is critical to our individual livelihoods and careers as well as to the success and viability of the Company. Your faithful attention to the requirements of the attached Policy is very much appreciated by the Board of Directors and by me personally.
Randy Harl
President and Chief Executive Officer
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Foreign Corrupt Practices Act Compliance Policy
