10 Misconceptions That Increase the Likelihood of FCPA Violations

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Chicago — April 14, 2011 — Grant Thornton EthicsPoint

Bill Olsen

David Childers

1."Based on our company profile, we don't have any FCPA risks."

2."We are a private company so we don't have to be concerned with the FCPA"

3."Our employees know our position on ethics because our policies spell it out."

4."As long as employees and agents have certified that they have not paid bribes, we have done enough."

5."These are challenging economic times. We need to make cutbacks in FCPA compliance, just as we have in all other areas of the business."

6."Our global whistleblower hotline is effective because no violations have been reported to date."

7."Since we don't have a controlling interest in our overseas business partnership, we have no need or authority to extend our compliance program and policies."

8."We will determine how to address an FCPA violation once a violation is identified."

9."Every business unit and sales office undergoes the same FCPA compliance testing, regardless of the type of business and location."

10."Common practice in our industry is to pay for airfare and lodging for foreign officials to attend conferences or trade shows."

www.ethicspoint.com/FCPA www.GrantThornton.com/FAIS

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