Terms & Policies

SUMMARY

As a global business with geographically distributed subsidiaries, Intercom maintains a commitment to running our business ethically, including complying with all applicable laws against corruption and bribery. The U.S. Foreign Corrupt Practices Act (“FCPA”) and U.K. Bribery Act of 2010 (“Bribery Act”) apply to Intercom’s worldwide activities, and Intercom is committed to observing the laws and regulations of the countries where we do business. This Statement supplements Intercom’s Code of Conduct and any similar supplements.

This Global Anti-Bribery Statement (the “Policy”) applies to Intercom’s employees, including directors, officers, and contractors, as well as third parties authorized to act on our behalf, including business partners. Under this Policy, employees and business partners may not pay or offer a bribe or kickback of any kind, including to Government Officials, or employees of government-owned or controlled companies, and in commercial transactions. Neither may our employees or business partners solicit or accept a bribe or kickback.

BRIBERY AND KICKBACKS

Neither our employees, nor our business partners are permitted to give, promise, offer, or authorize payment of anything of value to a government official as defined in the FCPA, or to any officials or civilians as described by the Bribery Act, in order to obtain or keep business or to secure some other improper advantage for Intercom. Conversely, neither our employees, nor our business partners are permitted to solicit or accept a bribe or kickback of any kind.

These prohibitions apply not only to money but to anything else of value, including providing business or job opportunities, facilitation payments (usually to government officials), donations, favorable contract terms, travel, gifts, and hospitality.

RECORDS AND REPORTING

We expect our employees and business partners to maintain accurate corporate books, records, and accounts. We encourage all employees and business partners to report, without fear of retaliation, any good faith suspicions that anyone acting on Intercom’s behalf is violating this Policy. No one will be punished for refusing to pay or accept a bribe or kickback, even if such refusal results in a loss of business to Intercom.

APPLICABILITY AND ENFORCEMENT

This Policy applies to all employees and business partners, and violation of the Policy may result in disciplinary action, up to and including termination of employment and/or the business relationship.