English - Colgate

Beyond the obvious or traditional government employees, remember that in some countries governmentworkers can include university professors, schoolteachers, dentists, veterinarians, doctors and state mediaemployees.For more detailed guidance on the Company’s policies in these areas, see “Colgate-Palmolive Guidelines onthe U.S. Foreign Corrupt Practices Act” and “Colgate-Palmolive Guidelines on Business Relationships withGovernment Entities,” which are found in the Company’s Business Practices Guidelines.Q:A:I understand that there are laws that prohibit the bribery of government officials. But does the law alsoprohibit the bribery of people who are not government officials?There are anti-bribery laws that prohibit bribery among private commercial parties; i.e., commercial bribery.These laws are just as important – and strictly enforced – as those prohibiting bribery of government officialsand employees.Always remember that Company policy and local law prohibit the bribery of anyone in the conduct of Companybusiness, whether a government official or private person.WE MANAGE RECORDS ACCORDING TO THE LAW.We comply with all laws and regulations relating to the management of Company records (includingphysical documents and electronic data).If the existence of a subpoena, litigation or an impending government investigation is known or reported toyou, immediately contact the Global Legal Organization. In such a case, you must retain all records that may beresponsive to the subpoena, are relevant to the litigation, or that may pertain to the investigation, regardless ofthe requirements of the Record Retention Program. You must not destroy or alter such records, as the improperdestruction of records could have serious consequences – including civil and/or criminal penalties – for theCompany and for you personally. If you have a question as to whether a record pertains to an investigation,litigation or a subpoena, contact the Global Legal Organization before disposing of the record in question.Q:A:How do I determine how long I must keep Company records and when I can dispose of them?Consult the Company’s Records Management intranet site at OurColgate.com > C-P Sites > Legal and Regulatoryor contact your local Records Coordinator (where applicable).WE COMPLY WITH INTERNATIONAL TRADE REGULATIONS.In the conduct of both its domestic and overseas operations, the Company fully complies with all applicablelaws – particularly U.S. laws – governing imports, exports and the conduct of business with non-U.S. entities.These laws contain limitations on the types of products that may be imported into the United States andthe manner of importation. They may also prohibit exports to, and most other transactions with, certaincountries. Cooperation with or participation in foreign boycotts of countries that are not boycotted bythe United States is also prohibited. Colgate people must conduct Company activities so as to fully complywith the laws of the countries in which they operate; however, there may be a time when there is a conflictbetween the laws of one country and those of the United States or Company policy. Should you becomeaware of such a conflict, you should notify your manager and consult the Global Legal Organization.For more detailed guidance on these laws and the countries to which they pertain, see “Colgate-PalmoliveInternational Business Activities Guidelines,” which are found in the Company’s Business PracticesGuidelines.22 CODE OF CONDUCT