From Steve Kreps To Alvaro Acevedo Manrique Ugalde Date 11 26 01 Subject FCPA infonnation Gentlemen Attached for your information is a memo distributed in 1999 regarding accounting for con dential payments Please call me if you have questions Regards Steve Kreps CC Joel Raymer A 9 9 9 trr vu Chiquita - MEMORANDUM Brands International T0 Distribution DATE November 30 1999 FROM Steven Kreps PHONE 513-768 4933 SUBJECT Accountinq for Con dential Payments This memorandum con rms current practices superceding previous guidance provided in memoranda from Bud White and Steve Tucker These practices help ensure operating units have accurate books and records and adequate systems of internal - accounting controls while allowing appropriate con dentiality There are two options for recording con dential payments These are the only two options unless you receive authorization to Use another method from W Tsacalis CBII Vice President and Controller 1 Follow standard Company practices in recording and classifying these transactions in the operating unit s books and records or 2 Record these transactions in a Manager s Expense account and comply with the following procedure a The General Manager will maintain the details and documents supporting the transactions recorded in the Manager s Expense account At least once each quarter the Manager of the San Jos Costa Rica Internal Audit Regional Of ce will perform an on-site review of each transaction recorded in the Manager s Expense account to determine whether The transaction was properly authorized documented and supported - Documentation and support exists for each transaction a list of such transactions should be prepared by the local controller and if required transactions were reported on an appropriate quarterly Foreign Cormpt Practices Act Compliance Certi cate During this review the Internal Audit Manager may request copies of supporting details and documents for further review with the Law Department b Internal Audit will periodically perform on-site reviews of disbursements at the operating units which use a Manager s Expense account to assure that the quarterly review referred to above includes all appropriate transactions 0 As part of the operating unit s TCS the General Manager's supervisor should approve the amount for the Manager's Expense account if an operating unit does not have a Manager's Expense account and would like to use one W Tsacalis Vice President and Controller should be contacted for authorization The Financial Administrative Policies relating to this subject are Internal Control pp 117 Quarterly Representation Letter 3-3 0 pp 1-6 Fiduciary Responsibilities of Local Chief Financial Of cers pp 1-2 FCPA commentary and the Company's Statement of Policies Procedures A-2 0 pp 1 3 and exhibits Please contact me if you have any questions Distribution M Aizpurua R Alarcon V Ayala T Battaglia M Broutin D Doyle R Flores G Fonseca MgrsExp99 doc C A Guzman P Horekens C Keiser R Kistinger A Larrar'iaga W Ligan M Mena J Mendoza J Mora T Moscoso B Nicolai M Oakley J Olivo R Olson J Ordman Page 2 A Palma B Paz R Redondo J Rivera P Rosenburg M Sims R Thomas W Tsacalis W Vespoti R Vezeau K Waugh D Wenninger C Zaldivar for 2000 add Laurent Potier to diStribution Page 3 This document is from the holdings of The National Security Archive Suite 701 Gelman Library The George Washington University 2130 H Street NW Washington D C 20037 Phone 202 994-7000 Fax 202 994-7005 nsarchiv@gwu edu