They (i) prohibit the making of improper payments directly or indirectly to foreign government officials, foreign political parties or officials thereof, or candidates for foreign political office in order to obtain or retain business or to direct business to any person and (ii) require Southwest to prepare and maintain accurate books, records, and accounts and to devise and maintain an adequate system of internal accounting controls. Blackout and Pre-Clearance Procedures Our Officers, Board members, and selected Employees are subject to quarterly restrictions on trading in Southwest securities during periods surrounding Southwest’s release of quarterly earnings.