Common use of Compliance with FCPA Clause in Contracts

Compliance with FCPA. None of the Company or its subsidiaries or, to the best knowledge of the Company, any director, officer, agent, employee or other person associated with or acting on behalf of the Company or its subsidiaries has (i) used any corporate funds for any unlawful contribution, gift, entertainment or other unlawful expense relating to political activity; (ii) made any direct or indirect unlawful payment to any foreign or domestic government official or employee from corporate funds; (iii) violated or is in violation of any provision of the Foreign Corrupt Practices Act of 1977, as amended (“FCPA”); or (iv) made any bribe, rebate, payoff, influence payment, kickback or other unlawful payment. The Company has instituted and maintains policies and procedures designed to ensure continued compliance with anti-bribery laws, including, but not limited to, the FCPA.

Compliance with FCPA. None of the Company or Issuer and its subsidiaries or, to the best knowledge of the CompanyIssuer, any director, officer, agent, employee or other person associated with or acting on behalf of the Company Issuer or its subsidiaries has (i) used any corporate funds for any unlawful contribution, gift, entertainment or other unlawful expense relating to political activity; (ii) made any direct or indirect unlawful payment to any foreign or domestic government official or employee from corporate funds; (iii) violated or is in violation of any provision of the Foreign Corrupt Practices Act of 1977, as amended 1977 (“FCPA”); or (iv) made any bribe, rebate, payoff, influence payment, kickback or other unlawful payment. The Company has Issuer and its subsidiaries have instituted and maintains maintain policies and procedures designed to ensure continued compliance with anti-bribery laws, including, including but not limited to, the FCPA.