Anti-Corruption Commitment Statement
Our Commitment
Barracuda Networks, Inc. is committed to maintaining the highest level of professional and ethical standards in the conduct of its business in all countries in which it operates or otherwise has business connections. Our reputation for honesty, integrity, and fair dealing is an invaluable component of our success as a company. Central to this commitment is our firm stance against corruption in any form.
To implement this commitment, we maintain a comprehensive Anti-Corruption Compliance Policy and Guidelines, managed by our Chief Legal Officer, to ensure compliance with the U.S. Foreign Corrupt Practices Act (“FCPA”) and other key anti-corruption laws, providing detailed guidance in key areas. Every person in our company must make a personal commitment to these standards.
Key Policy Elements:
Foreign Officials: We prohibit offering, promising, paying, or authorizing the payment of anything of value to foreign officials to influence their official duties. This includes officials at all government levels, employees of state-owned enterprises, and anyone acting in an official capacity.
Business Courtesies: Our policy provides clear guidelines for appropriate business courtesies, including:
- Requirements for gifts and promotional items
- Parameters for business entertainment and meals
- Guidelines for travel and travel-related expenses
- Documentation and approval processes
Third-Party Relationships: We carefully monitor our business relationships with joint venture partners, channel partners, distributors, resellers, and sales agents. Our policy requires:
- Due diligence before engagement
- Ongoing monitoring of activities
- Compliance with anti-corruption laws
- Clear documentation of all transactions
Financial Integrity: We maintain accurate books and records of all transactions, supported by appropriate internal controls to ensure all expenditures are properly documented and authorized.
Reporting Concerns: We encourage reporting of any potential improper business practices. Concerns can be reported:
- To the Legal Department
- Via our website: https://trust.barracuda.com/business-ethics/report-concerns
This public statement summarizes our commitment to anti-corruption compliance. A comprehensive policy and guidelines are maintained internally to implement these commitments effectively.
