Kickbacks


Kickbacks are any form of financial incentive provided in return for services selected and may be offered in many different ways.


Main Points:

All forms of kickbacks to employees or persons closely associated with employees are prohibited from customer and subcontractors.


Politely refuse all forms of gratuity and favors, then, expediently notify the Ethics Officer of the offer.


All Spectrum employees must comply with the Anti-Kickback Act.






What are examples of a kickback?

A: First of all, a kickback is a form of corruption that involves two parties agreeing that a portion of sales or profits will be improperly given, rebated or kicked back to the purchaser in exchange for making the deal. For example, a kickback might involve a supplier who offers a Spectrum associate a monthly payment equaling 5% of Spectrum’s purchases as an inducement to the associate to retain the supplier’s services. Kickbacks, like other forms of corruption, are unethical and prohibited under our Code, policies and the law.