Policy

Weyerhaeuser is committed to doing business honestly, with integrity, and complying with anti-bribery and anti-corruption laws in the U.S., Canada, and all other countries where we do business. This policy sets out our anti-bribery requirements and provides informative guidance to help you adhere to the law and make appropriate decisions in everyday situations. This policy applies to all of our business activities anywhere in the world, whether involving Government Officials or private commercial activities.

No Weyerhaeuser employee, officer, director, agent, representative, or other independent contractor acting on our behalf may offer or provide bribes or other improper benefits in order to obtain business or an unfair advantage.

Expectations

Weyerhaeuser has a zero tolerance policy concerning bribery or corruption and prohibits offering or receiving bribes or the offer or provision of Improper Payments or Improper Business Advantages.

There are four key principles to follow to comply with this policy:

  • You may not, directly or indirectly, offer or make a bribe or other improper or unjust payment or advantage to any person or entity.
  • You may not, directly or indirectly, request or accept a bribe or other improper or unjust payment or advantage from any person or entity.
  • You must maintain accurate books and records.
  • If you are responsible for managing applicable Third Parties, you must ensure that those parties fully understand and follow this policy in all activities related to Weyerhaeuser business.

Definitions

Bribe - Money, gifts, or anything of value intended to influence someone to do something that is illegal or improper, in violation of his or her duty, or to secure an Improper Business Advantage; may include non-monetary items of value, such as travel or entertainment, promotional or demonstrative items, or even the promise of a job.

Government Official – The term “Government Official” includes, but is not limited to, any official or employee of a government entity or organization, official or employee of a public international organization, member of a political party, candidate for political office, or any employee of a state-owned or controlled entity.

Improper Payment – Anything of value provided to a person intended to influence a business-related decision, including bribes, kickbacks, excessive gifts or entertainment, or anything else of value (tangible or intangible).

Improper Business Advantage – A benefit intended to obtain or retain business, such as awarding a contract, providing favors, or unfair access to information. For example, an Improper Business Advantage could include gaining access to sealed bid information, advanced access to RFP information, avoiding or paying reduced taxes, customs fees, or import duties, influencing whether certain legislation is enacted, or obtaining inside information.

Third Parties – Suppliers, vendors, or other intermediaries that interact with others on our behalf, such as agents, sales representatives, resellers, distributors, consultants, and other business partners.

Applicable Laws

Weyerhaeuser is subject to anti-bribery laws that include federal, state, provincial, and local laws in all jurisdictions where we conduct business. You must adhere to all relevant bribery laws, including the U.S. Foreign Corrupt Practices Act (“FCPA”). The FCPA applies to bribes or Improper Payments to any non-U.S. Government Official. Weyerhaeuser is also subject to other countries’ anti-bribery laws in the jurisdictions where it operates, including the Canadian Corruption of Foreign Public Officials Act (“CFPOA”) and the Japanese Unfair Competition Prevention Act (“UCPA”).

Anti-Bribery Requirements

This policy prohibits soliciting or accepting, or offering, promising, authorizing or giving bribes, other Improper Payments, or anything of value to or from anyone that 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. This includes any action taken directly or indirectly through a Third Party.

Third Parties Representing Weyerhaeuser

Weyerhaeuser is committed to doing business with Third Parties that share our commitment to ethical business conduct. Our expectation is that all Third Parties who conduct business on behalf of Weyerhaeuser, such as agents, sales representatives, distributors, consultants, suppliers, and other business partners, will comply with this policy and act in a manner consistent with our Code of Ethics. Anti-bribery laws apply whether a bribe is made directly by Weyerhaeuser or through any entity or person acting on our behalf, such as an agent, distributor, customs broker, or other representative.

Weyerhaeuser and its employees may be held liable for Improper Payments made by a Third Party if there is actual knowledge or reason to know that a bribe might be paid. We have an obligation to ensure our Third Parties understand this policy. We commit to only engaging reputable business partners and many of our partners will be required to complete a compliance due diligence procedure before being retained by the company.

Third Parties Interacting with Non-U.S. Government Officials: Due Diligence Requirements

Employees are required to submit Third Parties that interact with non-U.S. Government Officials to Ethics & Compliance for due diligence before engaging these Third Parties. To ensure that these Third Parties comply with this policy, arrangements with certain Third Parties must be maintained in written agreements approved by the Law Department and documented in accordance with our ethical business practices and legal requirements.

Written agreements with applicable Third Parties that interact with non-U.S. Government Officials must include detailed descriptions of the covered territories, including the relevant countries and/or regions, and the specific product coverage. Any new countries, territories, or regions and new product lines need to be included in the written agreement. These amendments or new contract scope must meet all Ethics & Compliance due diligence requirements.

All employees who manage Third Parties that interact with non-U.S. Government Officials are expected to follow the Weyerhaeuser Third Party Due Diligence Guidelines & Questionnaire. In addition to completing the company’s screening process, some Third Parties may also be required to complete Weyerhaeuser’s anti-bribery training or other audit related activities in order to maintain their agreements with the company.

Use of Funds and Company Records

All Weyerhaeuser employees are required to use company funds only for lawful purposes. All payments and activities must be accurately recorded and the company’s books, records, and accounts must accurately and fairly reflect all transactions and dispositions of assets. Employees may 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. Requests for false invoices or payments of expenses that are suspicious, excessive, or inadequately supported should be rejected and promptly reported to the appropriate function. Misleading, incomplete, or false entries in the company’s books and records are never acceptable and could lead to discipline up to and including termination.

Charitable Donations

Charitable giving has long been a Weyerhaeuser hallmark, but it can sometimes create risk. You may contribute to charitable organizations personally on your own behalf; however, contributions to charitable organizations or sponsorships by or on behalf of the company must be authorized by Weyerhaeuser. All charitable donations must be in accordance with anti-bribery laws and may not be intended to improperly influence the recipient. For more information about the company’s Giving Programs, please see the Citizenship page on Roots.

Employees may not use company resources to personally support charitable or other non-profit institutions without company approval. All donations must be for certified charitable organizations and not directed to individuals.

Political Donations

Employees must obtain approval in advance from the Government Affairs Department for all political contributions made by or on behalf of the company to any political parties, candidates for political office, or Government Officials. Employees are expected to comply with the company’s other policies dealing with the public sector, including the Government Affairs Policy.

Non-U.S. Investments

Employees may not make investments in any foreign entity or business on behalf of the company without adequate due diligence, a written agreement pertaining to anti-bribery compliance, and authorization from the Law Department. Please contact the Ethics & Compliance team with any questions about the parameters for non-U.S. investments.

Facilitation Payments

Even if not expressly prohibited by law in some jurisdictions, Weyerhaeuser employees are prohibited from making 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.

Promotional Activities

Weyerhaeuser only allows payments for the promotion or demonstration of the company’s products or services if proper and lawful under the laws 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 customer site visit. If you have any questions about legitimate promotional expenses, please contact the Ethics & Compliance team.

Always consult the Code of Ethics and this policy before providing anything of value to Government Officials. If you have any questions about whether an action is permissible, do not hesitate to contact the Ethics & Compliance team or the Law Department.

Training

Business leaders, employees, and Third Party representatives who interact with Government Officials are required 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-party agents complete anti-bribery training.

Participate in the company’s certificate of compliance process, which communicates and reaffirms compliance with this policy and identifies how to address concerns.

Consult with the Law Department, Ethics & Compliance, Government Affairs, or Internal Audit, as appropriate.

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.

Audience

This policy applies to all employees, officers, directors, independent contractors, agents, and representatives, or other person acting on behalf of the company. For employees in a collective bargaining unit, the labor agreement supersedes this policy if there is a conflict. Independent contractors, agents, and representatives are also required to maintain equivalent policies at their own organizations.

Reporting Violations

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, Ethics & Compliance, the Law Department, or a member of company management

  • Reports may also be made by telephone using the Weyerhaeuser EthicsLine at 1-800-716-3488 or online at https://www.WeyerhaeuserEthicsOnline.com.
  • 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.

Monitoring

To ensure compliance with anti-bribery laws, the Ethics & Compliance team, the Finance Department, Internal Audit, and other departments will conduct periodic monitoring of high risk transactions to assess the effectiveness of the compliance program. Employees are expected to cooperate with these monitoring activities and any related internal investigation.

Consequences

Violation of this policy may result in disciplinary action, up to and including termination of employment, in accordance with local law and applicable collective bargaining agreements.

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.

Related Resources

Assistance is available from the following resources:

Owner

SVP, General Counsel & Corporate Secretary

Last Updated

March 5, 2024

Related Resources

Assistance is available from the following resources: