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SCP-017Legal ComplianceDraft

International Requirements Policy

This policy establishes the framework for adapting the Company's US-based compensation plans to international jurisdictions. It mandates that all international compensation arrangements undergo local legal review and compliance verification before implementation, ensuring adherence to country-specific employment laws, tax regulations, data privacy requirements, and labor standards.

Version 1.0.02,767 wordsLegal Review Required

1Purpose & Objectives

This policy establishes the framework for adapting the Company's US-based compensation plans to international jurisdictions. It mandates that all international compensation arrangements undergo local legal review and compliance verification before implementation, ensuring adherence to country-specific employment laws, tax regulations, data privacy requirements, and labor standards.

  • Establish framework for adapting US-based compensation plans to international jurisdictions
  • Mandate local legal review for all international compensation arrangements
  • Ensure adherence to country-specific employment laws and tax regulations
  • Comply with data privacy requirements and labor standards in each jurisdiction

2Scope

Applies To

  • All the Company sales compensation plans implemented outside the United States
  • All sales representatives employed in international markets
  • Expatriate assignments involving compensation plan administration
  • Third-party sales agents and representatives in foreign jurisdictions
  • All divisions and business units operating internationally

3Definitions

Home Country

The country where the Company maintains its primary legal entity and where the employee's employment contract originates.

Host Country

The country where the employee physically works and where local employment laws apply.

Local Legal Review

Examination of compensation plan terms by qualified employment counsel licensed to practice law in the host country, specifically assessing compliance with local labor laws, tax regulations, and employment standards.

Split Payroll

Compensation arrangement where portions of an employee's pay are processed through different country payrolls to manage tax obligations, social security contributions, and compliance requirements across jurisdictions.

US Plan Baseline

The standard the Company US compensation plan structure (e.g., SCP-001 through SCP-016) used as the starting template for international adaptation.

Expatriate (Expat)

Employee transferred from their home country to work in a host country, typically maintaining home-country employment contract with host-country supplements.

Local National

Employee hired directly in the host country under local employment contract and terms.

Third-Country National (TCN)

Employee from one country working in a second country for a company headquartered in a third country.

4Key Provisions

Four core principles governing international compensation plan adaptation.

US Plans as Baseline Reference

All the Company international compensation plans shall use the corresponding US plan as the structural baseline, ensuring consistency in plan philosophy, alignment with corporate strategy, shared terminology, and streamlined administration.

Local Legal Review Mandatory

No exceptions. Every international compensation plan or plan modification must undergo review by qualified local employment counsel before implementation.

Compliance Over Consistency

When local law conflicts with US plan terms, local law always prevails. The Company prioritizes legal compliance over administrative convenience or global consistency.

Document All Adaptations

Every deviation from the US baseline plan must be:

  • Documented in writing
  • Approved by local legal counsel
  • Reviewed by Global HR and Finance
  • Maintained in the plan governance repository

5Compliance References

6Related Policies

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