COMPANY

GLOBAL TRADE POLICY

PMI Global Trade Policy Acknowledgement Form

All business activities pursuant to agreements with PMI shall be undertaken in accordance with the PMI Global Trade Policy (“PMI Policy”) and the Foreign Corrupt Practices Act of 1977, as amended, 15 U.S.C. §§ 78dd-1, et seq. (“FCPA”).

Section 1. International Trade Compliance

U.S. commodities subject to these agreements will be exported from the United States in accordance with the Export Administration Regulations and all other applicable U.S. laws and regulations. Reexport, transshipment, or diversion of these commodities contrary to U.S. law is prohibited.

Section 2. Anti-Corruption Compliance

No payments of money, or anything of value, shall be made, nor shall such be offered, promised or paid, directly or indirectly, to a government official (described herein) with the intent to influence the acts of such official in his official capacity or to induce him to use his influence with a government to obtain or retain business or gain an improper advantage in connection with any business venture or contract in which PMI is a participant.

A government official can include an official (elected, appointed, or career) or employee of a government, including inspectors, customs officials, police officers, etc. “Government” includes:

- Any governmental agency, department, instrumentality, ministry, commission, committee or any other body of a non-U.S. national, state or local government;

- An officer or employee of a government-owned or government-controlled business, corporation, company or organization (Note in some countries, an employee of the chamber of commerce or other pro-business entity may be considered a quasi-governmental official under the FCPA);

- An official or employee of a public international organization (e.g., Olympics Committees, United Nations, World Bank, World Trade Organization, World Customs Organization);

- An individual acting for or on behalf of a government or public international organization even though he may not be an employee of such government or organization (such as an uncompensated honorary official or a member of a royal family); or

- A political party or official thereof, or a candidate for political office.

The PMI Policy and the laws in some countries in which PMI operates, such as China, Hong Kong, Brazil, and Switzerland also prohibit commercial bribery, which refers to the practice of giving something of value to an intermediary (i.e., a customer’s employee), usually without the knowledge of upper management, and with the intention of influencing the customer’s commercial conduct. Accordingly, the PMI Policy prohibits PMI’s employees and agents from giving or receiving anything of significant value for the purpose of gaining an improper advantage in any transaction with actual or potential customers, vendors or suppliers.

Section 3. Acknowledgment

Any contracting party agrees immediately to inform PMI should information arise that the contracting party or any of its employees, agents, or related parties have engaged in any activities that appear to be in violation of the PMI Policy or the FCPA.

PMI reserves the right immediately to terminate a contract should PMI become aware that the contracting party has acted in a manner inconsistent with the PMI Policy or the FCPA.

Upon entering into agreements with PMI, as set forth above, each contracting party acknowledges that it has read, understood, and will comply with the foregoing PMI Policy.

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