considered government officials. In these situations, ordinary and reasonable business entertainment or gifts typically are allowed when they are customary and legal in the applicable community, provided they comply with Teradata policies. For more information on monetary thresholds, pre-approval requirements, and other considerations, please see the Teradata Gift and Entertainment Policy (CMP 912), the section of the Code that deals more specifically with Gifts and Entertainment below, or consult the Teradata Law Department before acting.

In some countries outside the U.S., facilitating payments to low-level government officials may be permitted under local law or business customs. Facilitating payments (sometimes called “grease” payments) are small payments, typically made in cash, to expedite the performance of routine governmental administrative actions, such as the processing of paperwork or granting of a permit. However, it can be difficult to tell when a facilitating payment crosses the line and becomes a bribe. For your protection and the protection of the company, Teradata prohibits all facilitating payments. You must immediately report all solicitations of facilitating payments, as well as solicitations of bribes or kickbacks, to the Teradata Law Department.

Teradata‘s Global Anti-Corruption Policy (CMP 904) expresses a Zero Tolerance for Bribery, Corruption, and Money-Laundering. All Teradata people must comply with this policy.

Teradata has also adopted various processes, tools, and controls related to third-party due diligence. These are intended to help screen out and prevent dealing with third parties who are known to be involved in corrupt activity. They also help assure extra and transparent precautions are taken to help ensure high risk or red-flagged third-party dealings are implemented in compliance with all applicable legal requirements and with due consideration of reputation risks. All Teradata people must comply with these processes and tools.

Export and Import Compliance

For Teradata to participate in the world market as a high-tech company, we must be particularly aware of international trade and immigration laws and restrictions. The export of goods and technology from most countries, including the United States, is strictly regulated. Communicating technical information to a person in another country (or to a citizen or representative of another country, even if that person is temporarily located within the same country as you) can be considered an export under the law. Whether a product or technology may be exported depends on several factors, including the nature of the item, the country of destination, and the intended end use and end user.

For more information on export activity and the laws that govern such activity, please see our Export Compliance Policy (CMP 919), or contact the Law Department.

Teradata also must comply with all applicable import laws and regulations. These laws typically govern what can be imported into a country, how the goods must be marked, classified and valued, and what duties or other taxes must be paid on them. The penalties for violations of both import and export regulations can be severe. If you are involved in the import process for Teradata, you should read and understand the company’s Import Compliance Policy (CMP 917). For guidance about import regulations, consult your organization’s designated import compliance liaison or the Teradata Law Department.

Teradata expects each of us to comply with all applicable import and export control laws and regulations. We supplement these laws and processes with third-party due diligence tools and controls designed to prevent and reduce the risk of bribery and corruption as well as to comply with trade restrictions and sanctions. We all are charged with ensuring we understand who our customers are, how our products will be used, and the end destinations of our products.