Foreign Corrupt Conduct Policy

Statement of Policy

Human Trafficking – Visa Fraud/Misuse

Continuity is proud to conduct business in a manner that is socially responsible. Because of this, Continuity employees and consultants adhere to a specific code of ethics and conduct expected in areas where improper activities could damage the company’s reputation and otherwise result in serious adverse consequences to the Company and to the employees involved.

This security policy covers your responsibility as a Continuity employee or consultant in personal conduct related to Human Trafficking and Visa fraud/misuse.

Human Trafficking

What is Human Trafficking?

Trafficking in Persons (TIP), or human trafficking, is both an international and a domestic crime that is often also associated with violations of labor, public health, and human rights standards.

The U.S. Department of Homeland Security (DHS) is responsible for investigating human trafficking, arresting traffickers and protecting victims.

Continuity will not tolerate employees or consultants in the recruitment, transportation, transfer, harboring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person, for the purpose of exploitation. Report suspected Human Trafficking activity to the Continuity Security office.

Visa Fraud/Misuse

What is a visa?

The U.S. visa is a document, obtained at a U.S. Embassy or Consulate, granting a foreign traveler permission to apply for admission into the United States at a port of entry. It is not a guarantee of entry into the United States. Department of Homeland Security inspectors determine if, and for how long, an alien is admitted.

There are two types of visas:

  • Immigrant visa: For people who intend to live permanently in the United States, as provided by the Immigration and Nationality Act
  • Nonimmigrant visa: For people who wish to visit the United States temporarily–for tourism, medical treatment, business, temporary work, or study

What are typical types of visa fraud?

  • Presenting false documents to apply for a visa
  • Concealing facts that would disqualify one from getting a visa, like a criminal history in the alien’s home country
  • The sale, trafficking, or transfer of otherwise legitimate visas
  • Misrepresenting the reasons for requiring a visa
  • Counterfeiting, forgery, or alteration of a visa

Criminals commit visa fraud to:

  • smuggle aliens into the United States
  • flee from prosecution
  • facilitate drug trafficking and terrorist operations
  • assist with other crimes, like remaining in the United States illegally

Continuity will not tolerate employees or consultants, whom forge, counterfeit, alter, or falsely make any immigrant or nonimmigrant visa. Report suspected Visa Fraud/Misuse activity to the Continuity Security office.

Continuity would like employees and consultants to understand that any person who has a certain degree of connection to the United States and engages in foreign corrupt practices applies to the Foreign Corrupt Practices Act (FCPA).

The Act also applies to any act by U.S. businesses, foreign corporations trading securities in the United States, American nationals, citizens, and residents acting in furtherance of a foreign corrupt practice whether or not they are physically present in the United States. In the case of foreign natural and legal persons, the Act covers their actions if they are in the United States at the time of the corrupt conduct.

Any Continuity employee or consultant investigated and found engaging in any foreign corrupt conduct will be immediately removed from employment or association.