Is AT&T required to adhere to its Codes of Conduct throughout the term of the Atwell Suites agreement?
Atwell_Suites Franchise · 2025 FDDAnswer from 2025 FDD Document
AT&T maintains a Code of Conduct and a Code of Business Ethics ("Codes") and requires that its employees participate in annual compliance training. The Codes are generally consistent with IHG's Supplier Code of Conduct. AT&T shall maintain the Codes throughout the term of the Agreement and adhere to such Codes.
12. FCPA AND BRIBERY ACT
(U.S.)
AT&T maintains a Foreign Corrupt Practices Act and Anti-Bribery Compliance Policy, as well as an Anti-Money Laundering Policy ("Policies") and requires that its employees participate in annual compliance training. The Policies are consistent with and reflective of the United States Foreign Corrupt Practices Act of 1977, as amended and the UK Bribery Act of 2010. AT&T shall maintain the Policies throughout the term of the Agreement and adhere to such Policies.
13. OFAC AND OTHER SANCTIONS
- 13.1 In performing the obligations set forth in this Agreement, Eligible Participant and AT&T each shall at all times comply with the economic and trade sanctions administered by the United States Office of Foreign Assets Control ("OFAC"), including all Executive Orders and implementing regulations.
Source: Item 23 — Receipts (FDD pages 99–486)
What This Means (2025 FDD)
According to the 2025 Atwell Suites FDD, AT&T is required to maintain and adhere to its Code of Conduct and Code of Business Ethics throughout the term of the agreement. These codes are generally consistent with IHG's Supplier Code of Conduct. This ensures that AT&T, as a service provider or partner, operates under ethical and compliant business practices during their engagement with Atwell Suites.
Additionally, AT&T must maintain and adhere to its Foreign Corrupt Practices Act and Anti-Bribery Compliance Policy, as well as an Anti-Money Laundering Policy throughout the agreement's term. These policies align with the United States Foreign Corrupt Practices Act of 1977 and the UK Bribery Act of 2010. This requirement emphasizes the importance of legal and ethical conduct in international business dealings related to the Atwell Suites franchise.
Furthermore, both Atwell Suites franchisees and AT&T must comply with the economic and trade sanctions administered by the United States Office of Foreign Assets Control (OFAC). This includes ensuring that no transactions or services are provided to individuals or entities in violation of U.S. economic sanctions. This provision highlights the need for vigilance in adhering to international laws and regulations to avoid potential legal and financial repercussions.