Cross Brand Design Services(R)7

GIFT, TRAVEL OR ENTERTAINMENT FOR FOREIGN

OFFICIALS

Any gift, travel or entertainment for anyone who may be a foreign official must comply with the

Foreign Corrupt Practices Act, all other anti-corruption laws including the laws of other countries

which the Company does business in, and the Company’s International Compliance Policy. No

gift, travel or entertainment may be provided to a foreign official unless the Legal department

has granted written pre-clearance for such travel, entertainment or gift. All such gift,

entertainment and travel expenses of any amount must be recorded appropriately in the books

and records of the Company, identifying the date and amount in question, the recipient’s name,

the business need for the expense, and a summary of compliance with the Company’s pre-

approval process.