This Privacy Policy governs the manner in which The Wetherall Company LLC collects, uses, maintains and discloses information collected from users (each, a "User") of the twcpsa.com website ("Site"). This privacy policy applies to the Site and all products and services offered by The Wetherall Company LLC.
Personal identification information
We may collect personal identification information from Users in a variety of ways, including, but not limited to, when Users visit our site, register on the site, place an order, respond to a survey, and in connection with other activities, services, features or resources we make available on our Site. Users may be asked for, as appropriate, name, email address. Users may, however, visit our Site anonymously. We will collect personal identification information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personally identification information, except that it may prevent them from engaging in certain Site related activities.
Non-personal identification information
We may collect non-personal identification information about Users whenever they interact with our Site. Non-personal identification information may include the browser name, the type of computer and technical information about Users means of connection to our Site, such as the operating system and the Internet service providers utilized and other similar information.
Web browser cookies
Our Site may use "cookies" to enhance User experience. User's web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. User may choose to set their web browser to refuse cookies, or to alert you when cookies are being sent. If they do so, note that some parts of the Site may not function properly.
How we use collected information
The Wetherall Company LLC may collect and use Users personal information for the following purposes:
Personal identification information
We may collect personal identification information from Users in a variety of ways, including, but not limited to, when Users visit our site, register on the site, place an order, respond to a survey, and in connection with other activities, services, features or resources we make available on our Site. Users may be asked for, as appropriate, name, email address. Users may, however, visit our Site anonymously. We will collect personal identification information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personally identification information, except that it may prevent them from engaging in certain Site related activities.
Non-personal identification information
We may collect non-personal identification information about Users whenever they interact with our Site. Non-personal identification information may include the browser name, the type of computer and technical information about Users means of connection to our Site, such as the operating system and the Internet service providers utilized and other similar information.
Web browser cookies
Our Site may use "cookies" to enhance User experience. User's web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. User may choose to set their web browser to refuse cookies, or to alert you when cookies are being sent. If they do so, note that some parts of the Site may not function properly.
How we use collected information
The Wetherall Company LLC may collect and use Users personal information for the following purposes:
- To improve customer service, Information you provide helps us respond to your customer service requests and support needs more efficiently.
- To improve our Site, We may use feedback you provide to improve our products and services.
- To run a promotion, contest, survey or other Site feature, To send Users information they agreed to receive about topics we think will be of interest to them.
- To send periodic emails, We may use the email address to send User information and updates pertaining to their order. It may also be used to respond to their inquiries, questions, and/or other requests. We may use the email address to send company newsletters, updates, related product or service information, etc. If at any time the User would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.
- To send periodic emails, We may use the email address to send User information and updates pertaining to their order. It may also be used to respond to their inquiries, questions, and/or other requests. We may use the email address to send company newsletters, updates, related product or service information, etc. If at any time the User would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.
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How we protect your information
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site.
Sharing your personal information
We do not sell, trade, or rent Users personal identification information to others. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above.We may use third party service providers to help us operate our business and the Site or administer activities on our behalf, such as sending out newsletters or surveys. We may share your information with these third parties for those limited purposes provided that you have given us your permission.
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Changes to this privacy policy
The Wetherall Company LLC has the discretion to update this privacy policy at any time. When we do, we will revise the updated date at the bottom of this page. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.
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Your acceptance of these terms
By using this Site, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.
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Contacting us:
If you have any questions about this Privacy Policy, the practices of this site, or your dealings with this site, please contact us at:
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The Wetherall Company LLC Website: twcpsa.com Location: 89 Beech Street Islip, NY 11751 USA Phone: 516-449-5661 Email: info@twcpsa.com
The Wetherall Company LLC Website: twcpsa.com Location: 89 Beech Street Islip, NY 11751 USA Phone: 516-449-5661 Email: info@twcpsa.com
THE WETHERALL COMPANY LLC dba TWCPSA CODE OF CONDUCT AND CORRUPTION POLICY
INTRODUCTION
TWCPSA is committed to conducting its business ethically and in compliance with all
applicable laws and regulations, including the U.S. Foreign Corrupt Practices Act (FCPA), the
United Kingdom Bribery Act (UKBA) and similar laws in other countries that prohibit improper
payments to obtain a business advantage. This document describes TWCPSA’s Policy
prohibiting bribery and other improper payments in the conduct of TWCPSA business
operations and employee responsibilities for ensuring implementation of the Policy. Questions
about the Policy or its applicability to particular circumstances should be directed to
Wendy Wetherall, Owner & President of TWCPSA. Note: Wendy Wetherall is also a CFRE, Certified Fundraising Executive ID# 60470. Ethics and accountability are central to fundraising professionalism. All holders of the CFRE credential pledge to abide by CFRE Accountability Standards.
POLICY OVERVIEW
TWCPSA strictly prohibits bribery or other improper payments in any of its business
operations. This prohibition applies to all business activities, anywhere in the world, whether
involving government officials or other commercial enterprises. A bribe or other improper
payment to secure a business advantage is never acceptable and can expose individuals and
TWCPSA to possible criminal prosecution, reputational harm or other serious consequences.
This Policy applies to everyone at TWCPSA, including all officers, employees and agents or
other intermediaries acting on TWCPSA’s behalf. Each officer and employee of TWCPSA
has a personal responsibility and obligation to conduct TWCPSA’s business activities
ethically and in compliance with all applicable laws based on the countries wherein TWCPSA
does business. Failure to do so may result in disciplinary action, up to and including dismissal.
Improper payments prohibited by this policy include bribes, kickbacks, excessive gifts or
entertainment, or any other payment made or offered to obtain an undue business advantage.
These payments should not be confused with reasonable and limited expenditures for gifts,
business entertainment and other legitimate activities directly related to the conduct of
TWCPSA’s business.
TWCPSA has developed a comprehensive program for implementing this Policy, through
appropriate guidance, training, investigation and oversight. Wendy Wetherall] has
overall responsibility for the program, supported by the executive leadership of TWCPSA.
Wendy Wetherall is responsible for giving advice on the interpretation and application
of this policy, supporting training and education, and responding to reported concerns.
The prohibition on bribery and other improper payments applies to all business activities, but is
particularly important when dealing with government officials. The U.S. Foreign Corrupt
Practices Act and similar laws in other countries strictly prohibit improper payments to gain a
business advantage and impose severe penalties for violations. The following summary is
intended to provide personnel engaged in international activities a basic familiarity with
applicable rules so that inadvertent violations can be avoided and potential issues recognized in
time to be properly addressed.
The FCPA, UKBA and other anti-bribery laws make it unlawful to bribe a foreign official to gain
an “improper business advantage.” An improper business advantage may involve efforts to
obtain or retain business, as in the awarding of a government contract, but also can involve
regulatory actions such as licensing or approvals. Examples of prohibited regulatory bribery
include paying a foreign official to ignore an applicable customs requirement. A violation can
occur even if an improper payment is only offered or promised and not actually made, it is made but fails to achieve the desired result, or the result benefits someone other than the giver (for example, directing business to a third party). Also, it does not matter that the foreign official may have suggested or demanded the bribe, or that a company feels that it is already entitled to the government action.
Who is a “foreign official”? A “foreign official” can be essentially anyone who exercises
governmental authority. This includes any officer or employee of a foreign government
department or agency, whether in the executive, legislative or judicial branch of government,
and whether at the national, state or local level. Officials and employees of government-owned
or controlled enterprises also are covered, as are private citizens who act in an official
governmental capacity. Foreign official status often will be apparent, but not always. In some
instances, individuals may not consider themselves officials or be treated as such by their own
governments but nevertheless exercise authority that would make them a “foreign official” for
purposes of anti-bribery laws. Personnel engaged in international activities are responsible
under this Policy for inquiring whether a proposed activity could involve a foreign official or an
entity owned or controlled by a foreign government, and should consult with Wendy Wetherall when questions about status arise.
What types of payments are prohibited? The FCPA prohibits offering, promising or giving
“anything of value” to a foreign official to gain an improper business advantage. In addition to
cash payments, “anything of value” may include:
• Gifts, entertainment or other business promotional activities;
• Covering or reimbursing an official’s expenses;
• Offers of employment or other benefits to a family member or friend of a foreign official;
• Political party and candidate contributions;
• Charitable contributions and sponsorships.
Other less obvious items provided to a foreign official can also violate anti-bribery laws.
Examples include in-kind contributions, investment opportunities, stock options or positions in
joint ventures, and favorable or steered subcontracts. The prohibition applies whether an item
would benefit the official directly or another person, such as a family member, friend or business
associate.
Under the law, TWCPSA and individual officials or employees may be held liable for
improper payments by an agent or other intermediary if there is actual knowledge or reason to
know that a bribe will be paid. Willful ignorance – which includes not making reasonable inquiry
when there are suspicious circumstances – is not a defense, and it also does not matter
whether the intermediary is itself subject to anti-bribery laws. All employees therefore must be
alert to potential “red flags” in transactions with third parties.
TWCPSA and its affiliates must keep accurate books and records that reflect transactions
and asset dispositions in reasonable detail, supported by a proper system of internal accounting
controls. These requirements are implemented through TWCPSA’s standard accounting
rules and procedures, which all personnel are required to follow without exception. Special care
must be exercised when transactions may involve payments to foreign officials. Off-the-books
accounts should never be used. Facilitation or other payments to foreign officials should be
promptly reported and properly recorded, with respect to purpose, amount and other relevant
factors. Requests for false invoices or payment of expenses that are unusual, excessive or
inadequately described must be rejected and promptly reported. Misleading, incomplete or false entries in TWCPSA’s books and records are never acceptable.
TWCPSA has established detailed standards and procedures for the selection, appointment
and monitoring of agents, consultants and other third parties. These standards and procedures
must be followed in all cases, with particular attention to “red flags” that may indicate possible
legal or ethical violations. Due diligence ordinarily will include appropriate reference and
background checks, written contract provisions that confirm a business partner’s
responsibilities, and appropriate monitoring controls. Personnel working with agents and other
third parties should pay particular attention to unusual or suspicious circumstances that may
indicate possible legal or ethics concerns, commonly referred to as “red flags.” The presence of
red flags in a relationship or transaction requires greater scrutiny and implementation of
safeguards to prevent and detect improper conduct. Appointment of an agent or other third
party ordinarily requires prior approval by an appropriate senior manager, description of the
nature and scope of services provided in a written contract, and appropriate contractual
safeguards against potential violations of law or TWCPSA policy.
This Policy imposes on all personnel specific responsibilities and obligations that will be
enforced through standard disciplinary measures and properly reflected in personnel
evaluations. All officers, employees and agents are responsible for understanding and
complying with the Policy, as it relates to their jobs. Every employee has an obligation to:
• Be familiar with applicable aspects of the Policy and communicate them to
subordinates;
• Ask questions if the Policy or action required to take in a particular situation is unclear;
• Properly manage and monitor business activities conducted through third-parties;
• Be alert to indications or evidence of possible wrongdoing; and
• Promptly report violations or suspected violations through appropriate channels.
Any employee who has reason to believe that a violation of this Policy has occurred, or may
occur, must promptly report this information to his or her supervisor, the next level of
supervision, or Wendy Wetherall. Alternatively, information may be reported in confidence by calling 516-449-5661.
Retaliation in any form against an employee who has, in good faith, reported a violation or
possible violation of this Policy is strictly prohibited. Employees who violate this Policy will be
subject to disciplinary action, up to and including dismissal. Violations can also result in
prosecution by law enforcement authorities and serious criminal and civil penalties. When
seeking guidance and/or reporting concerns, the following contacts and reporting options are
available to you: Wendy@twcpsa.com, 516-449-5661.
INTRODUCTION
TWCPSA is committed to conducting its business ethically and in compliance with all
applicable laws and regulations, including the U.S. Foreign Corrupt Practices Act (FCPA), the
United Kingdom Bribery Act (UKBA) and similar laws in other countries that prohibit improper
payments to obtain a business advantage. This document describes TWCPSA’s Policy
prohibiting bribery and other improper payments in the conduct of TWCPSA business
operations and employee responsibilities for ensuring implementation of the Policy. Questions
about the Policy or its applicability to particular circumstances should be directed to
Wendy Wetherall, Owner & President of TWCPSA. Note: Wendy Wetherall is also a CFRE, Certified Fundraising Executive ID# 60470. Ethics and accountability are central to fundraising professionalism. All holders of the CFRE credential pledge to abide by CFRE Accountability Standards.
POLICY OVERVIEW
TWCPSA strictly prohibits bribery or other improper payments in any of its business
operations. This prohibition applies to all business activities, anywhere in the world, whether
involving government officials or other commercial enterprises. A bribe or other improper
payment to secure a business advantage is never acceptable and can expose individuals and
TWCPSA to possible criminal prosecution, reputational harm or other serious consequences.
This Policy applies to everyone at TWCPSA, including all officers, employees and agents or
other intermediaries acting on TWCPSA’s behalf. Each officer and employee of TWCPSA
has a personal responsibility and obligation to conduct TWCPSA’s business activities
ethically and in compliance with all applicable laws based on the countries wherein TWCPSA
does business. Failure to do so may result in disciplinary action, up to and including dismissal.
Improper payments prohibited by this policy include bribes, kickbacks, excessive gifts or
entertainment, or any other payment made or offered to obtain an undue business advantage.
These payments should not be confused with reasonable and limited expenditures for gifts,
business entertainment and other legitimate activities directly related to the conduct of
TWCPSA’s business.
TWCPSA has developed a comprehensive program for implementing this Policy, through
appropriate guidance, training, investigation and oversight. Wendy Wetherall] has
overall responsibility for the program, supported by the executive leadership of TWCPSA.
Wendy Wetherall is responsible for giving advice on the interpretation and application
of this policy, supporting training and education, and responding to reported concerns.
The prohibition on bribery and other improper payments applies to all business activities, but is
particularly important when dealing with government officials. The U.S. Foreign Corrupt
Practices Act and similar laws in other countries strictly prohibit improper payments to gain a
business advantage and impose severe penalties for violations. The following summary is
intended to provide personnel engaged in international activities a basic familiarity with
applicable rules so that inadvertent violations can be avoided and potential issues recognized in
time to be properly addressed.
The FCPA, UKBA and other anti-bribery laws make it unlawful to bribe a foreign official to gain
an “improper business advantage.” An improper business advantage may involve efforts to
obtain or retain business, as in the awarding of a government contract, but also can involve
regulatory actions such as licensing or approvals. Examples of prohibited regulatory bribery
include paying a foreign official to ignore an applicable customs requirement. A violation can
occur even if an improper payment is only offered or promised and not actually made, it is made but fails to achieve the desired result, or the result benefits someone other than the giver (for example, directing business to a third party). Also, it does not matter that the foreign official may have suggested or demanded the bribe, or that a company feels that it is already entitled to the government action.
Who is a “foreign official”? A “foreign official” can be essentially anyone who exercises
governmental authority. This includes any officer or employee of a foreign government
department or agency, whether in the executive, legislative or judicial branch of government,
and whether at the national, state or local level. Officials and employees of government-owned
or controlled enterprises also are covered, as are private citizens who act in an official
governmental capacity. Foreign official status often will be apparent, but not always. In some
instances, individuals may not consider themselves officials or be treated as such by their own
governments but nevertheless exercise authority that would make them a “foreign official” for
purposes of anti-bribery laws. Personnel engaged in international activities are responsible
under this Policy for inquiring whether a proposed activity could involve a foreign official or an
entity owned or controlled by a foreign government, and should consult with Wendy Wetherall when questions about status arise.
What types of payments are prohibited? The FCPA prohibits offering, promising or giving
“anything of value” to a foreign official to gain an improper business advantage. In addition to
cash payments, “anything of value” may include:
• Gifts, entertainment or other business promotional activities;
• Covering or reimbursing an official’s expenses;
• Offers of employment or other benefits to a family member or friend of a foreign official;
• Political party and candidate contributions;
• Charitable contributions and sponsorships.
Other less obvious items provided to a foreign official can also violate anti-bribery laws.
Examples include in-kind contributions, investment opportunities, stock options or positions in
joint ventures, and favorable or steered subcontracts. The prohibition applies whether an item
would benefit the official directly or another person, such as a family member, friend or business
associate.
Under the law, TWCPSA and individual officials or employees may be held liable for
improper payments by an agent or other intermediary if there is actual knowledge or reason to
know that a bribe will be paid. Willful ignorance – which includes not making reasonable inquiry
when there are suspicious circumstances – is not a defense, and it also does not matter
whether the intermediary is itself subject to anti-bribery laws. All employees therefore must be
alert to potential “red flags” in transactions with third parties.
TWCPSA and its affiliates must keep accurate books and records that reflect transactions
and asset dispositions in reasonable detail, supported by a proper system of internal accounting
controls. These requirements are implemented through TWCPSA’s standard accounting
rules and procedures, which all personnel are required to follow without exception. Special care
must be exercised when transactions may involve payments to foreign officials. Off-the-books
accounts should never be used. Facilitation or other payments to foreign officials should be
promptly reported and properly recorded, with respect to purpose, amount and other relevant
factors. Requests for false invoices or payment of expenses that are unusual, excessive or
inadequately described must be rejected and promptly reported. Misleading, incomplete or false entries in TWCPSA’s books and records are never acceptable.
TWCPSA has established detailed standards and procedures for the selection, appointment
and monitoring of agents, consultants and other third parties. These standards and procedures
must be followed in all cases, with particular attention to “red flags” that may indicate possible
legal or ethical violations. Due diligence ordinarily will include appropriate reference and
background checks, written contract provisions that confirm a business partner’s
responsibilities, and appropriate monitoring controls. Personnel working with agents and other
third parties should pay particular attention to unusual or suspicious circumstances that may
indicate possible legal or ethics concerns, commonly referred to as “red flags.” The presence of
red flags in a relationship or transaction requires greater scrutiny and implementation of
safeguards to prevent and detect improper conduct. Appointment of an agent or other third
party ordinarily requires prior approval by an appropriate senior manager, description of the
nature and scope of services provided in a written contract, and appropriate contractual
safeguards against potential violations of law or TWCPSA policy.
This Policy imposes on all personnel specific responsibilities and obligations that will be
enforced through standard disciplinary measures and properly reflected in personnel
evaluations. All officers, employees and agents are responsible for understanding and
complying with the Policy, as it relates to their jobs. Every employee has an obligation to:
• Be familiar with applicable aspects of the Policy and communicate them to
subordinates;
• Ask questions if the Policy or action required to take in a particular situation is unclear;
• Properly manage and monitor business activities conducted through third-parties;
• Be alert to indications or evidence of possible wrongdoing; and
• Promptly report violations or suspected violations through appropriate channels.
Any employee who has reason to believe that a violation of this Policy has occurred, or may
occur, must promptly report this information to his or her supervisor, the next level of
supervision, or Wendy Wetherall. Alternatively, information may be reported in confidence by calling 516-449-5661.
Retaliation in any form against an employee who has, in good faith, reported a violation or
possible violation of this Policy is strictly prohibited. Employees who violate this Policy will be
subject to disciplinary action, up to and including dismissal. Violations can also result in
prosecution by law enforcement authorities and serious criminal and civil penalties. When
seeking guidance and/or reporting concerns, the following contacts and reporting options are
available to you: Wendy@twcpsa.com, 516-449-5661.
This document was last updated on October 11, 2024
Privacy Policy & Code of Conduct and Corruption Policy