Anti-Corruption and OFAC Policy

The Anti-Corruption and OFAC Policy governs compliance with the U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act of 2010 and with U.S. economic sanctions issued by the Office of Foreign Assets Control of the U.S. Treasury Department (“OFAC”). Specifically, the Policy prohibits (1) offering or making improper payments in all business dealings, whether with the government or in the private sector; and (2) any dealings directly or indirectly involving countries, entities and individuals targeted by embargoes and sanctions programs. The Policy applies to the Company’s employees, directors, officers, members, principals and third-party intermediaries assisting or doing business on the Company’s behalf. Annual training and compliance certifications are required, and the Company maintains a robust vendor screening and due diligence regime as part of its procurement process.