Effective implementation of the Company’s anti‐corruption policy involves the following: (i ) provision of specific policy guidance, procedural safeguards, and internal controls pertaining to the offering or giving of gifts, which are prohibited or regulated by law; (ii ) policy implementation is reinforced by related policies such as the Company’s Corporate Governance Guidelines for Suppliers, which prohibits bribery in connection with business transactions involving the Company and its suppliers, as well as Company policies on Gifts, Entertainment, and Sponsored Travel; Whistleblowing; Supplier/Contractor Relations; and Conflict of Interest; and (iii ) appropriate monitoring and preventive measures that include internal controls, training and communication programs, whistleblowing facilities, third party due diligence, and enforcement mechanisms.