Anti-Bribery Policy

In this area…

Use of Funds

Use company funds only for lawful purposes.

Bribes and Other Payments

Not solicit or accept, or offer, promise, authorize or give bribes or other improper payments to or from anyone, directly or indirectly.

• “bribe” means money, gifts or anything of value to influence someone to do something that is improper, in violation of his or her duty or illegal, or to secure an improper advantage
• “improper payments” includes bribes, kickbacks, excessive gifts or entertainment, or anything of value improperly offered, given or received
• “anything of value” means any form of benefit, and includes, but is not limited to, cash, gifts, entertainment, donations, services, or discounts

Kickbacks

Not give or accept anything of value to or from any person that would improperly impact, or might be perceived to improperly impact, the outcome of any business transaction or may place Weyerhaeuser or such other person in a position of obligation.

Third Parties

Do business with third parties that share our commitment to ethical business conduct. Our expectation is that all third parties who provide services to us or act on our behalf, such as agents, sales representatives, distributors, consultants, suppliers, and other business partners, will comply with this policy.

Company Records

Ensure that all payments and activities are accurately recorded and that the company’s books, records and accounts accurately and fairly reflect all transactions and dispositions of assets.

Not make or authorize false, inaccurate, misleading or incomplete entries or create any "off-the-book" accounts or otherwise attempt to circumvent the company’s system of internal accounting controls.

Maintain a system of internal accounting controls sufficient to provide adequate corporate supervision over all accounting and reporting activities.

Agents

Conduct appropriate due diligence on third-party agents, reach written agreement with this policy before engaging agents, and where appropriate require agents to take our anti-bribery training.

Political Contributions

Obtain approval in advance from the Corporate Affairs Department for all contributions by or on behalf of the company to any political parties, candidates for political office, or government officials.

Comply with the company’s other policies dealing with the public sector, including our Government Affairs Policy.

Foreign Investments

Make no investment in any foreign entity or business without adequate due diligence and written agreement on compliance with this policy.

Facilitation Payments

Not make facilitation payments (also known as “expediting” or “grease” payments), which are small payments or fees to government officials to secure or speed up routine government action. There are very limited exceptions, such as when facilitation payments are officially published by a government agency and available to the general public or in exceptional emergency situations when an employee’s personal safety is at risk. In such situations, the facilitation payment should be immediately reported to the Law Department.

Promotional Activities

Only allow payments for the promotion or demonstration of the company’s products or services if proper and lawful under the law of the local country. Such payments must be reasonable in amount and legitimately related to our sales and marketing activities. Examples are courtesy gifts, product samples, and meals, travel and lodging related to a site visit