definiens: means, SAMR and each of its Representatives not, directly orindirectly, ( a ) making, offering, authorizing, providing or paying anything of value in any form, whether in money, property, services or otherwise to any Government Official, or other Person charged with similar public or quasi - publicduties, or to any customer, supplier, or any other Person, or to any employee thereof, or failing to disclose fully anysuch payments in violation of the laws of any relevant jurisdiction to ( i ) obtain favorable treatment in obtaining orretaining business for it or any of its Affiliates, ( ii ) pay for favorable treatment for business secured, ( iii ) obtain specialconcessions or for special concessions already obtained, for or in respect of it or any of its Affiliates, in each casewhich would have been in violation of any applicable Law, ( iv ) 7 influence an act or decision of the recipient ( including a decision not to act ) in connection with the Person ’s or itsAffiliate ’s business, ( v ) induce the recipient to use his or her influence to affect any government act or decision inconnection with the Person ’s or its Affiliate ’s business or ( vi ) induce the recipient to violate his or her duty of loyalty tohis or her organization, or as a reward for having done so ; ( b ) engaging in any transactions, establishing or maintainingany fund or assets in which it or any of its Affiliates shall have proprietary rights that have not been recorded in thebooks and records of it or any of its Affiliates ; ( c ) making any unlawful payment to any agent, employee, officer ordirector of any Person with which it or any of its Affiliates does business for the purpose of influencing such 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 of bribery, fraud, or any other unlawful payment under theapplicable Laws of any jurisdiction where it or any of its Affiliates conducts business or is registered ; or, ( f ) if suchPerson or any of its Representatives is a Government Official, improperly using his or her position as a GovernmentOfficial to influence the award of business or regulatory approvals to or for the benefit of such Person, itsRepresentatives or any of their business operations, or failing to recuse himself or herself from any participation as aGovernment Official in decisions relating to such Person, its Representatives or any of their business operations