Common use of Compliance with Anti-Corruption, Money Laundering and Import Laws; Export Controls and Economic Sanctions Clause in Contracts

Compliance with Anti-Corruption, Money Laundering and Import Laws; Export Controls and Economic Sanctions. (i) Neither any Subject Company, nor any of the officers, directors, employees, agents, consultants, distributors, resellers, representatives, sales intermediaries or other Persons acting on behalf of any Subject Company, has: (A) directly or indirectly, given, promised, offered, authorized the offering of or paid anything of value to any public official, in each case, for purposes of (1) influencing any act or decision of any public official in such official’s official capacity, (2) inducing such public official to do or omit to do any act in violation of such official’s lawful duty, (3) securing any improper advantage or (4) inducing such public official to use such official’s influence with a Governmental Authority, or commercial enterprise owned or controlled by any Governmental Authority (including state-owned or -controlled facilities), in order to assist such Subject Company in obtaining or retaining business; or (B) taken any action in violation of any applicable anti-corruption Law, including, without limitation, the FCPA, the U.K. Bribery Act of 2010 and any other applicable anti-corruption or anti-bribery Law of any Governmental Authority of any jurisdiction applicable to such Subject Company. There is no pending or threatened action, Proceeding or investigation (whether internal or by a Governmental Authority), with respect to any actual or potential violation of any applicable anti-corruption Law relating to any Subject Company. Each Subject Company has in place adequate controls to ensure compliance with any applicable anti-corruption Laws, including but not limited to the “books and records” provisions of the FCPA or other similar provisions in any applicable anti-corruption law.

Compliance with Anti-Corruption, Money Laundering and Import Laws; Export Controls and Economic Sanctions. (i) Neither any Subject Company, nor any of the officers, directors, employees, agents, consultants, distributors, resellers, representatives, sales intermediaries or other Persons acting on behalf of any Subject Company, has: (A) directly or indirectly, given, promised, offered, authorized the offering of of, or paid anything of value to any public official, in each case, for purposes of (1) influencing any act or decision of any public official in such official’s official capacity, (2) inducing such public official to do or omit to do any act in violation of such official’s lawful duty, (3) securing any improper advantage or (4) inducing such public official to use such official’s influence with a Governmental Authority, or commercial enterprise owned or controlled by any Governmental Authority (including state-owned or -controlled facilities), in order to assist such Subject Company in obtaining or retaining business; or (B) taken any action in violation of any applicable anti-corruption Law, including, without limitation, the FCPA, the U.K. Bribery Act of 2010 and any other applicable anti-corruption or anti-bribery Law of any Governmental Authority of any jurisdiction applicable to such Subject Company. There is no pending or threatened action, Proceeding or investigation (whether internal or by a Governmental Authority), with respect to any actual or potential violation of any applicable anti-corruption Law relating to any Subject Company. Each Subject Company has in place adequate controls to ensure compliance with any applicable anti-corruption Laws, including but not limited to the “books and records” provisions of the FCPA or other similar provisions in any applicable anti-corruption law.

Compliance with Anti-Corruption, Money Laundering and Import Laws; Export Controls and Economic Sanctions. (i) A. Neither any Subject Company, nor any of the officers, directors, employees, agents, consultants, distributors, resellers, representatives, sales intermediaries or other Persons acting on behalf of any Subject Company, has: (A1) directly or indirectly, given, promised, offered, authorized the offering of of, or paid anything of value to any public official, in each case, for purposes of (1A) influencing any act or decision of any public official in such official’s official capacity, (2B) inducing such public official to do or omit to do any act in violation of such official’s lawful duty, (3C) securing any improper advantage or (4D) inducing such public official to use such official’s influence with a Governmental Authority, or commercial enterprise owned or controlled by any Governmental Authority (including state-owned or -controlled facilities), in order to assist such Subject Company in obtaining or retaining business; or (B2) taken any action in violation of any applicable anti-corruption Law, including, without limitation, the Foreign Corrupt Practices Act of 1977 (“FCPA”), 15 U.S.C. §§ 78dd-1, et seq., the U.K. Bribery Act of 2010 and any other applicable anti-corruption or anti-bribery Law of any Governmental Authority of any jurisdiction applicable to such Subject Company. There is no pending or threatened action, Proceeding proceeding or investigation (whether internal or by a Governmental Authority), with respect to any actual or potential violation of any applicable anti-corruption Law relating to any Subject Company. Each Subject Company has in place adequate controls to ensure compliance with any applicable anti-corruption Laws, including but not limited to the “books and records” provisions of the FCPA or other similar provisions in any applicable anti-corruption law.