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ANTI-CORRUPTION POLICY

All employees must comply with anti-corruption laws. Such laws prohibit the receipt/payment of bribes and kickbacks (monetary or otherwise) as well as promises for such to occur whether it is with another individual or entity or public officials. Extortion is also unacceptable to the Company.

An employee must not accept or offer any gift or be involved in any entertainment which might place him/her under an obligation or could be reasonably viewed as improperly influencing business transactions or placing him/her in a potential or actual situation of conflict of interest. (Gifts include but are not limited to cash, gift cards, presents, entertainment and non-business activities.)

If any infringement on this rule is found, it will be investigated and reported to the management and if necessary be made known to the management of the person making/receiving the gift.

If an employee needs any clarification for the policy above, he/she should consult the Head of Department or Management.