COMPLIANCE POLICY

PMI Global Trade Policy

All business activities pursuant to agreements with Parker-Migliorini International, LLC, including any of its subsidiaries and affiliates (“PMI”), shall be undertaken in accordance with PMI’s Global Trade Compliance Policy (the “Policy”) and the anti-corruption laws applicable to such activities, such as the Foreign Corrupt Practices Act of 1977, Article 322 of the Swiss Criminal Code, the EU Criminal Law Convention on Corruption, the Brazil Clean Companies Act, The PRC Anti-Unfair Competition Law and Chapter VIII of the PRC Criminal Law.

Section 1.  International Trade Compliance

U.S. commodities subject to sales agreements between PMI and its clients 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.

All other commodities subject to such sales agreements will be exported and shipped in accordance with the applicable laws governing the export and international trade of such commodities.

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.

PMI’s Policy and the laws in some countries in which PMI operates, such as the People’s Republic of China, Hong Kong SAR, 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.  PMI’s 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.  Contracting Party Obligations

Any contracting party having information that it or any of its employees, agents, or related parties have engaged in any activities that appear to be in violation of PMI’s Policy or applicable trade or anti-corruption laws and regulations agrees immediately to inform PMI of the same.  PMI reserves the right immediately to terminate a contract should PMI become aware that the contracting party has acted in a manner inconsistent with PMI’s Policy or applicable trade or anti-corruption laws and regulations.

Any party entering into any contract with PMI is deemed by PMI to have read, understood, and expressed its commitment to comply with PMI’s Policy.

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