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Six Flags Global Anti-Corruption

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Six Flags Global Anti-Corruption Updated January 2016 SIX FLAGS ENTERTAINMENT CORPORATION GLOBAL ANTI-CORRUPTION POLICY SECTION 1 SCOPE AND PURPOSE The purpose of this policy is to set forth the commitment of Six Flags Entertainment Corporation (“Six Flags” or the “Company”) to uphold the highest standards of business integrity and to comply with all applicable domestic and international anti-bribery and corruption rules, regulations and laws, including the U.S. Foreign Corrupt Practices Act (“FCPA”). This policy provides employees and agents of the Company with information and guidance on how to identify, respond to, and avoid situations that could potentially violate applicable anti-corruption laws, both domestic and international. SECTION 2 DEFINITIONS 2.1 Bribe – A payment or promise to give money, fee, commission, credit, gift, gratuity or anything of value to a person in a position of influence for purposes of improperly persuading the person. 2.2 Foreign Government Official – A political party candidate or any person acting on behalf of an international (non-U.S.) government or agency, department, instrumentality or other entity of such government (e.g., national, state or local governmental bodies). Also included are any employees of businesses or entities owned (in whole or in part), controlled or operated by a government agency. This term shall also mean any person who is employed by a Public International Organization, including but is not limited to, organizations such as the United Nations and World Bank. 2.3 Gift – Any item that is provided to a non-Six Flags individual or entity that is completely gratuitous and where the giving party receives nothing of value in return. 2.4 Business Partner – Any agent, representative, distributor, joint venture partner, contractor, supplier, sales person, broker, consultant, or any other third party, in any way engaged to act on the Company’s behalf in commercial matters anywhere in the world. 2.5 Third Party Intermediary – Any Business Partner engaged to act on Six Flags’ behalf with Foreign Government Officials or international government entities. SECTION 3 APPLICABLE LAWS 3.1 U.S. Law 3.1.1 Anti-Bribery Law: The FCPA’s anti-bribery provisions make it unlawful for businesses and individuals to make corrupt payments to Foreign Government Officials in exchange for their assistance in obtaining or retaining a business advantage. This means that: nothing of value can be offered, promised, or given either directly or indirectly to induce or influence a Foreign Government Official in an effort to obtain or retain a business advantage. A “business advantage” is interpreted broadly by FCPA enforcement authorities to mean not only direct advantages (such as sales contracts) but also indirect advantages (such as favorable tax treatment or favors or other preferential treatment). Items “of value” include not only the payment of cash or cash-equivalents, but other items of value such as gifts, lavish entertainment, charitable donations or political contributions. Even non-tangible items, such as an offer or promise of employment, can be considered “something of value” intended to improperly influence a Foreign Government Official. 3.1.2 Accounting Provisions: The FCPA has two parts. In addition to the anti- bribery provisions, it also requires U.S. and foreign public companies that are listed on stock exchanges in the U.S. maintain accurate books and records and a system of reasonable internal accounting controls. The accounting provisions also prohibits individuals and businesses from knowingly falsifying books and records or knowingly circumventing (or failing to implement) a system of internal controls. 3.1.3 Indirect Payments: U.S. companies may also be liable for knowing of a corrupt payment made on its behalf by its Business Partners to a Foreign Government Official. “Knowing” includes a conscious disregard—that is, ignoring the circumstances surrounding a transaction that would make a reasonable person suspicious that a violation may occur. Red Flags: The following “red flags” may raise FCPA concerns and should be investigated before entering into any agreement or before providing any payment or thing of value. These include, but are not limited to: Dealing with a Business Partner that objects to providing FCPA representations and warranties. -2- Dealing with a Business Partner that is known to be related to, or otherwise associated with, a current or former Foreign Government Official or that has been recommended by a Foreign Government Official. Dealings with a Foreign Government Official or entity that has a reputation for corruption. Requests for large or unusual payments or commissions. Requests for payments made through non-obvious third parties or to an account located in another country where the payee does no business. Unsupported travel or entertainment expenses. Employees should consult with the Company’s General Counsel should they encounter any other circumstance raising a suspicion that a bribe may be involved. 3.1.4 Penalties: FCPA anti-bribery violations carry criminal penalties. Corporations can face fines up to $2 million and individuals can face fines up to $100,000 plus imprisonment of up to five years. The U.S. Government may also require disgorgement of up to twice the profits gained through the unlawful act. Violations of the FCPA’s accounting provisions can also carry criminal penalties: individuals may face fines up to $5 million and imprisonment for up to 20 years, while corporations may be subject to fines up to $25 million. Additional indirect costs of an FCPA violation can be significant: millions of dollars investigating the violation and taking measures to avoid future violations. FCPA violations also significantly damage reputations and disrupt normal business operations 3.2 Other Anti-Corruption Laws Other nations have enacted anti-corruption laws (including China, India, and Brazil), and the U.S. and other countries are signatories to several anti-corruption conventions and treaties, including the United Nations Convention against Corruption, and the OECD Convention against Bribery. Several countries’ anti- corruption laws go beyond bribery of public officials to include commercial bribery involving non-government parties. For example, the Peoples Republic of China (PRC) prohibits most conduct that violates the FCPA, but also prohibits commercial bribery not involving state-controlled entities. The U.K. Bribery Act prohibits both public and private sector bribery, and also prohibits the unlawful receipt of a bribe. India’s Prevention of Corruption Act (1988) is primarily aimed -3- at prohibiting public servants from accepting a bribe in any form—including gifts or hospitality that are likely to influence official acts. Employees should consult with the General Counsel for guidance on these laws and conventions. SECTION 4 GUIDELINES 4.1 Certifications. All written agreements with Business Partners that may have a relationship, or interact, with a Foreign Government Official should include certifications (or “representations and warranties”) by such parties that they are in compliance with the FCPA and other applicable anti-corruption laws. Where such Business Partners do not have a formal written agreement in place with Six Flags, a separate FCPA compliance certification should be signed and renewed on a periodic basis. The required Certification language appears as Attachment 2 to this policy. Higher risk Business Partners may warrant the enhanced compliance Certification language provided at Attachment 3. 4.2 Due Diligence. Certain Business Partners (including, but not limited to, Third Party Intermediaries) must undergo due diligence prior to commencing a business relationship with Six Flags. The required Due Diligence Procedure is provided as Attachment 4 to this policy. 4.3 Periodic Assessment. As part of its Internal Audit procedures, the Company will periodically assess the effectiveness of its FCPA compliance program. This may include review of: invoices, expense reimbursements, and Business Partner payment statements in order to detect any suspicious or problematic payments. 4.4 Expense Report Accuracy. The Company’s accounting systems are designed to ensure the proper recording of expenses incurred for FCPA-sensitive activities, including travel, hospitality and gifts for Foreign Government Officials. It is each employee’s duty to include accurate and detailed descriptions of all expenses in order to accurately document the purpose of each expense that is submitted in an expense report or otherwise reimbursed or paid for by Six Flags. Employees must follow applicable standards, principles, laws and Company practices for accounting and financial reporting. 4.5 Gifts and Hospitality. In general, no gift or entertainment should be given or accepted if it could, or if it creates the appearance that it could, improperly influence the Company’s business relationships, create obligations, violate the law or Six Flags’ policies, or otherwise cause potential embarrassment to the Company. Six Flags’ Code of Business Conduct and Ethics provides that, as a general principle, gifts and hospitality extended by Six Flags must: Be consistent with common courtesies usually associated with accepted business practice in a given culture; Be legal, reasonable and approved by park or corporate management; -4- Be in a form that will not be construed as a bribe or pay-off; and Comply with applicable law and the policy of the recipient’s organization. See the Guidelines
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