definiens: means all applicable Laws prohibiting a Person ( and / o r its Representatives ) from(a ) making, offering, authorizing, providing or paying anything of value in any form, whether in money, prop erty, services or otherwiseto any Governmental Authority, Government Oﬃcial, or ot her Person charged with similar public or quasi - public du ties, or to anycustomer, supplier, or any other Person, or to any employe e thereof, or failing to disclose fully any such payments in violation of thelaws of any relevant jurisdiction to ( i ) obtain favorabl e treatment in obtaining or retaining business for it or any of its Aﬃliates, ( ii ) payfor favorable treatment for business secured, ( iii ) obtai n special concessions ( or to pay for special concessions already ob tained ), foror in respect of it or any of its Aﬃliates, in each case wh ich would have been in violation of any applicable Law, ( iv ) inﬂuence an actor decision of the recipient ( including a decision not to act ) in connection with the Person ’s or its Aﬃliate ’s busi ness, ( v ) induce therecipient to use his or her inﬂuence to aﬀect any governmen t act or decision in connection with the Person ’s or its Aﬃ liate ’s businessor ( vi ) induce the recipient to violate his or her duty o f loyalty to his or her organization, or as a reward for having done so ; ( b)engaging in any transactions, establishing or maintaining any fund or assets in which it or any of its Aﬃliates shal l have proprietaryrights that have not been recorded in the books and recor ds of it or any of its Aﬃliates ; ( c ) making any unlawful p ayment to anyagent, employee, oﬃcer or director of any Person with wh ich it or any of its Aﬃliates does business for the purpose of inﬂuencingsuch agent, employee, oﬃcer or director to do business with it or any of its Aﬃliates ; ( d ) violating any provision of applicable Anti - Corruption Laws ; ( e ) making any payment in the nature o f bribery, fraud, or any other unlawful payment under the Law of anyjurisdiction where it or any of its Aﬃliates conducts busin ess or is registered ; or ( f ) if such Person or any of its Re presentatives is aGovernment Oﬃcial, improperly using his or her position a s a Government Oﬃcial to inﬂuence the award of business or regulatoryapprovals to or for the beneﬁt of such Person, its Represen tatives or any of their business operations, or failing t o recuse himself orherself from any participation as a Government Oﬃcial in decisions relating to such Person, its Representatives or any of theirbusiness operations