Weyerhaeuser is committed to doing business honestly and with integrity and to comply with anti-bribery and anti-corruption laws in the U.S., Canada and all other countries where we do business. This policy applies to all of our business activities anywhere in the world, whether involving government officials or private commercial activities.
Weyerhaeuser employees are expected to comply with the following standards:
In this area…
Our standard is to…
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
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.
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.
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.
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.
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.
Make no investment in any foreign entity or business without adequate due diligence and written agreement on compliance with this policy.
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.
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
Senior leaders and employees who may deal with foreign government officials are expected to participate in anti-bribery training on a regular basis.
Leaders’ Additional Responsibilities
Provide guidance to employees to ensure compliance with this policy.
Ensure that appropriate employees and third parties complete anti-bribery training.
Participate in the company’s certificate of compliance process which communicates and reaffirms compliance with this policy and identifies concerns.
Consult with the Law Department, Ethics and Business Conduct or Internal Audit, as appropriate.
This policy applies to all employees. For employees in a collective bargaining unit, the labor agreement supersedes this policy if there is a conflict.
If you are aware of a practice or transaction that gives rise to a question under this policy, you should report it to your manager.
Reports will be treated confidentially to the extent allowed by law.
Reports may be made anonymously.
Weyerhaeuser prohibits retaliation for good faith reports of suspected misconduct.
Violation of this policy may result in disciplinary action, up to and including termination of employment.
Additionally, violation of anti-bribery laws (including the U.S. Foreign Corrupt Practices Act) can result in civil and criminal penalties for individuals involved and for the company. Individuals may be fined and/or imprisoned as the result of criminal prosecution.
SVP, General Counsel & Corporate Secretary
July 3, 2020
Assistance is available from the following resources: