Company A is a large US engineering company woth global operations jn more than $50$ countires, includijf a nukber that have a high risk of corruption, such as foreign country. COMPANY A$\text{'}$s stock ks listed on a national US stock exchange. In conducting business internationally, company A$\text{'}$s officers and employees come into regular contact with foreign officials, including officials in various ministires and state owned entities. At antrade show, company A has a booth at which it offers free pens, hats, t shirts, and orher similar promotional items woth company A$\text{'}$s logo$.$ Company A also serves free coffee, other beverages, and snacks at the booth. Some of the visitors to the booth are foreign officials. Is company A in violation of the FCPA?