Anti-Bribery Guidance for
Teledyne Third Parties
Requirements for Doing Business with Teledyne
As a representative of Teledyne in the marketplace, we have certain
requirements related to your business operations (These items are part ofyour agreement with Teledyne):
1. Compliance with Teledyne’s Code of Conduct for Service Providers.
2. Compliance with all applicable laws and regulations. We strictly prohibit
the use of bribery or corruption in any form to gain or retain business.
No exceptions.
3. Bribery is illegal and contrary to Teledyne’s values.
4. Compliance with United States export regulations and other applicable
export regulations that may apply to the transaction.
5. Promptly investigate and remediate ethics and compliance concernsthat may arise in your business operations.

Always Operate with the Highest Ethical Standards

1What is the Foreign Corrupt Practices Act (FCPA) and How Does it Apply to Your Business?
•The FCPA makes it illegal to offer something of value to aforeign official (including an employee of a state-ownedentity) for the purpose of obtaining an unfair advantage (e.g.,obtaining or retaining business). It also has a provision thatmakes it illegal for records to reflect payments or hospitality
inaccurately.

•The FCPA applies wherever you are because you are
representing Teledyne, which is a U.S. Corporation.

•Businesses and individuals can be prosecuted for engaging
in bribery or corruption.

•Every country has laws prohibiting bribery of their own
government officials, and many have laws which prohibitcommercial bribery and bribery of foreign government
officials. For example, the United Kingdom has the UK
Bribery Act, Canada has the Corruption of Foreign Public
Officials Act and China has various anti-corruption laws.
When acting on behalf of Teledyne, you are expected tofollow all the laws that may apply.

FAQ #1: What is “anything ofvalue?”
Anything of value canliterally be anything! Money,
charitable donations, loans,golf outings, tickets to sports
events, travel expenses,
meals, entertainment,gifts, gift cards, offers ofemployment, and personalfavors.

The reputations of both companies are at stake!

What Limitations Does Teledyne Place on Your Business with Respect to Hospitality?
•All trips or entertainment must have a legitimate businesspurpose. Someone from your company must be inattendance. Examples of legitimate trips include attendanceat technical training or factory acceptance testing.

•Trips cannot exceed the time required to accomplish thebusiness purpose. No extra days for sight-seeing will beallowed.

•No trips or other benefits should be provided to anyspouse, family member or friend of a business partner. Ifspouses, friends, or family members will join, they must be
responsible for paying their own fare.

•All expenses should be reasonable and appropriately tied tothe business being conducted. E.g., no first-class airfare orgold watches.

•Payments can be inappropriate even if they are madeindirectly, e.g., to a charity associated with a customer or to acustomer’s family member disguised as a personal gift.

•These restrictions apply even if a Teledyne third party or anemployee of the Teledyne third party is paying.

•All travel should be cleared with the customer’s employer
in advance. Teledyne third parties should book the travel
themselves rather than reimburse the customer. Cashpayments are never acceptable.

FAQ #2: Our customers arecoming a long way to attend
a conference. What kind ofentertainment can I provide
them consistent with theseGuidelines?
You may entertain
your customers but theentertainment must not takeup a substantial portion of theagenda for the trip. Examplesof reasonable entertainment
would be a two-hour bus
tour of the city you are in,or a play or baseball gamein the evening. Day-longsightseeing outings, spa days,
trips to amusement parks,
or inappropriate or adultentertainment generally will
not be permitted.

Violations of these requirements may result in termination of your contract with Teledyne!

2Test Your Knowledge
Scenario 1:
Sam works for a Teledyne distributor. The distributor has
spent months trying to win a sale for Teledyne, but thecompetition is steep. The buyer at the customer tells Sam
that it can guarantee Sam’s company will win the bid if
Sam can give the buyer a $10,000 payment. Can Sam ask
Teledyne to discount the product $10,000 more, so he will
have the extra $10,000 to give to the customer?
Answer:
No! Even though the $10,000 USD would be paid by Sam and not Teledyne, it would violate anti-bribery
laws, even if Teledyne did not know about it. No offers of payment or for things of value can be madeby any Teledyne third party to unfairly win a sale.
Scenario 2:
Amad is an employee for a Teledyne Distributor. Amad’s
customer needs to come to Amad’s facility to test the Teledyne
product before acceptance. Amad wants to fly the customer ina few days early and pay for him to go sight-seeing, in hopesthat this gesture will improve his chances of winning a followon contract. Can Amad do this?
Answer:No! Trips cannot exceed the time required for the businesspurpose. Teledyne would not allow its distributor to do this, and it could potentially be illegal.
Scenario 3:
Stefan is a Teledyne Sales Representative. Stefan sells into
countries in Asia where it is still custom to provide gifts
to business associates as a gesture of good will. Stefan
decides to start leaving gold jewelry in his customers’
offices and suitcases from time to time to let them knowthat he considers them important business partners. Is
Stefan’s activity reasonable?
Answer:
No! Gold jewelry would be considered lavish andinappropriate. Any gifts provided should be nominal in value and transparent (not hidden or secret) andtied to business, such as promotional items that bear company logos.
Scenario 4:
Zahara is a Teledyne consultant. Teledyne has engaged
Zahara to obtain certification from the local government
for Teledyne’s products to be permissible to sell in
the country. The government agent tells Zahara that
unfortunately the products fail to meet the certification
requirements, but he can look past it, if she pays him$5,000 USD. Can Zahara make the payment so long as it
is with her own money instead of her company’s money?
Answer:No! It does not matter who specifically makes the payment. No one can make a payment on behalf ofTeledyne to gain an unfair advantage. This would be against Teledyne policy and illegal.

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Raising Compliance Questions or Concerns• Teledyne Director of Ethics and Anti-Corruption, Tina Luther at
Tina.Luther@teledyne.com• Teledyne FLIR Deputy General Counsel, Tim Stevenson at
Tim.Stevenson@teledyneflir.com• Teledyne General Counsel – Digital Imaging and Europe, Nick Wargent at
Nick.Wargent@teledyne.com• Teledyne General Counsel and Chief Compliance Officer, Melanie Cibik at
Melanie.Cibik@teledyne.com• Our confidential Ethics Help Line is available to our partners 24/7 – if you
file a report, provide as much detail as possible to allow us to properly
investigate.
• 1-877-666-6968 or www.teledyne.ethicspoint.com(International dialing instructions are available atwww.teledyne.ethicspoint.com.)

TELEDYNETECHNOLOGIESEverywhereyoulook4TMJune 2021