Common use of Compliance with International Trade & Anti-Corruption Laws Clause in Contracts

Compliance with International Trade & Anti-Corruption Laws. (a) None of the Group Companies, nor, to the Company’s knowledge, any of their respective officers, directors or employees, any of their other Representatives, or any other Persons acting for or on behalf of any of the foregoing, is or has been, since its applicable date of incorporation, (i) a Person named on any Sanctions and Export Control Laws-related list of designated Persons maintained by a Governmental Entity; (ii) located, organized or resident in a country or territory which is itself the subject of or target of any Sanctions and Export Control Laws; (iii) an entity owned, directly or indirectly, by one or more Persons described in clause (i) or (ii); or (iv) otherwise engaging in dealings with or for the benefit of any Person described in clauses (i) through (iii) or any country or territory which is or has, since January 1, 2018, been the subject of or target of any Sanctions and Export Control Laws (at the time of this Agreement, Russia, Belarus, the Crimea region of Ukraine, Cuba, Iran, North Korea, Venezuela, Sudan and Syria). (b) None of the Group Companies, nor any of their respective officers, directors or employees, nor, to the Company’s knowledge, any of their Representatives, or any other Persons acting for or on behalf of any of the foregoing has, to the Company’s knowledge, since its applicable date of incorporation, directly or indirectly, (i) made, offered, authorized, facilitated, solicited, promised, paid or received any unlawful contribution, gift, entertainment, bribes, kickbacks, financial or other advantage, or anything else of value, regardless of form or amount, to or from any Person, (ii) made or paid any contributions, directly or indirectly, to a domestic or foreign political party or candidate that violate Anti-Corruption Laws, (iii) otherwise made, offered, received, authorized, promised or paid any improper payment prohibited under any Anti-Corruption Laws or (iv) been the subject of any Proceeding or disclosure, or except as otherwise disclosed on Section 3.21(b) of the Company Disclosure Schedule, any internal report or investigation, in each case, regarding any violation or alleged violation under Sanctions and Export Control Laws or Anti-Corruption Laws, and no such Proceeding is pending or, to the Company’s knowledge, has been threatened.

Compliance with International Trade & Anti-Corruption Laws. (a) None Since Atlas’ incorporation, none of the Group CompaniesAtlas, norany of its officers, directors or employees or, to the Company’s knowledge, any of their respective officers, directors or employees, any of their its other RepresentativesRepresentative, or any other Persons acting for or on behalf of any of the foregoing, is or has been, since its applicable date of incorporation, (i) a Person named on any Sanctions and Export Control Laws-related list of designated Persons maintained by a Governmental Entity; (ii) located, organized or resident in a country or territory which is itself the subject of or target of any Sanctions and Export Control Laws; (iii) an entity owned, directly or indirectly, by one or more Persons described in clause (i) or (ii); or (iv) otherwise engaging in dealings with or for the benefit of any Person described in clauses (i) through - (iii) or any country or territory which is or has, since January 1, 2018Atlas’ incorporation, been the subject of or target of any Sanctions and Export Control Laws (at the time of this Agreement, Russia, Belarus, the Crimea region of Ukraine, Cuba, Iran, North Korea, Venezuela, Sudan and Syria). (b) None Since Atlas’ incorporation, none of the Group CompaniesAtlas, nor any of their respective its officers, directors or employees, noremployees or, to the Company’s knowledge, any of their Representativesits other Representative, or any other Persons acting for or on behalf of any of the foregoing has, to the Company’s knowledge, since its applicable date of incorporation, directly or indirectly, has (i) made, offered, authorized, facilitated, solicited, promised, paid or received any unlawful contribution, gift, entertainment, bribes, kickbacks, financial kickbacks or other advantage, or anything else of value, regardless of form or amount, similar payments to or from any Person, (ii) made or paid any contributions, directly or indirectly, to a domestic or foreign political party or candidate that violate Anti-Corruption Laws, or (iii) otherwise made, offered, received, authorized, promised or paid any improper payment prohibited under any Anti-Corruption Laws or (iv) been the subject of any Proceeding or disclosure, or except as otherwise disclosed on Section 3.21(b) of the Company Disclosure Schedule, any internal report or investigation, in each case, regarding any violation or alleged violation under Sanctions and Export Control Laws or Anti-Corruption Laws, and no such Proceeding is pending or, to the Company’s knowledge, has been threatened.

Compliance with International Trade & Anti-Corruption Laws. (a) None of the Group Companies, nor, to the Company’s knowledge, any of their respective officers, directors or employees, any of their other Representatives, or any other Persons acting for or on behalf of any of the foregoing, is or has been, since its applicable date of incorporationJanuary 1, 2018, (i) a Person named on any Sanctions and Export Control Laws-related list of designated Persons maintained by a Governmental Entity; (ii) located, organized or resident in a country or territory which is itself the subject of or target of any Sanctions and Export Control Laws; (iii) an entity owned, directly or indirectly, by one or more Persons described in clause (i) or (ii); or (iv) otherwise engaging in dealings with or for the benefit of any Person described in clauses (i) through (iii) or any country or territory which is or has, since January 1, 2018, been the subject of or target of any Sanctions and Export Control Laws (at the time of this Agreement, Russia, Belarus, the Crimea region of Ukraine, Cuba, Iran, North Korea, Venezuela, Sudan and Syria). (b) None of the Group Companies, nor any of their respective officers, directors or employees, nor, to the Company’s knowledge, any of their Representatives, or any other Persons acting for or on behalf of any of the foregoing has, to the Company’s knowledge, since its applicable date of incorporationJanuary 1, 2016, directly or indirectly, (i) made, offered, authorized, facilitated, solicited, promised, paid or received any unlawful contribution, gift, entertainment, bribes, kickbacks, financial or other advantage, or anything else of value, regardless of form or amount, to or from any Person, (ii) made or paid any contributions, directly or indirectly, to a domestic or foreign political party or candidate that violate Anti-Corruption Laws, (iii) otherwise made, offered, received, authorized, promised or paid any improper payment prohibited under any Anti-Corruption Laws or (iv) been the subject of any Proceeding or disclosure, or except as otherwise disclosed on Section 3.21(b) of the Company Disclosure Schedule, any internal report or investigation, in each case, regarding any violation or alleged violation under Sanctions and Export Control Laws or Anti-Corruption Laws, and no such Proceeding is pending or, to the Company’s knowledge, has been threatened.

Compliance with International Trade & Anti-Corruption Laws. (a) None of Neither the Group Companies, Company nor, to the Company’s knowledge, any of their respective officers, directors or employees, any of their other its Representatives, or any other Persons acting for or on behalf of any of the foregoing, is or has been, since its applicable date the incorporation of incorporationthe Company, (i) a Person named on any Sanctions and Export Control Laws-related list of designated Persons maintained by a Governmental Entity; (ii) located, organized or resident in a country or territory which is itself the subject of or target of any Sanctions and Export Control Laws; (iii) an entity owned, directly or indirectly, by one or more Persons described in clause (i) or clause (ii); or (iv) otherwise engaging in dealings with or for the benefit of any Person described in clauses clause (i) through clause (iii) or any country or territory which is or has, since January 1, 2018the incorporation of the Company, been the subject of or target of any Sanctions and Export Control Laws (at the time of this Agreement, Russia, Belarus, the Crimea region of Ukraine, Cuba, Iran, North Korea, Venezuela, Sudan and Syria); or (v) engaging in any export, re-export, transfer or provision of any goods, software, technology, data or service without, or exceeding the scope of, any required or applicable licenses or authorizations under all applicable Sanctions and Export Control Laws. The Company maintains policies and procedures reasonably designed to comply with the ITAR. (b) None of Neither the Group Companies, nor any of their respective officers, directors or employees, Company nor, to the Company’s knowledge, any of their its Representatives, or any other Persons acting for or on behalf of any of the foregoing has, to the Company’s knowledge, since its applicable date of incorporation, directly or indirectly, has (i) made, offered, authorized, facilitated, solicited, promised, paid or received any unlawful contribution, gift, entertainment, bribes, kickbacks, financial kickbacks or other advantage, or anything else of value, regardless of form or amount, similar payments to or from any Person, (ii) made or paid any contributions, directly or indirectly, to a domestic or foreign political party or candidate that violate Anti-Corruption Laws, or (iii) otherwise made, offered, received, authorized, promised or paid any improper payment prohibited under any Anti-Corruption Laws or (iv) been the subject of any Proceeding or disclosure, or except as otherwise disclosed on Section 3.21(b) of the Company Disclosure Schedule, any internal report or investigation, in each case, regarding any violation or alleged violation under Sanctions and Export Control Laws or Anti-Corruption Laws, and no such Proceeding is pending or, to the Company’s knowledge, has been threatened.

Compliance with International Trade & Anti-Corruption Laws. (a) None of Neither the Group Companies, nor, to the Company’s knowledge, any of their respective officers, directors or employees, any of their other Representatives, Representatives or any other Persons in each case to the extent acting for or on behalf of any of the foregoing, Group Companies is or has been, since its applicable date of incorporationDecember 31, 2017, (i) a Person named on any Sanctions and Export Control Laws-related list of designated Persons maintained by a Governmental Entity; (ii) located, organized or resident in a country or territory which is itself the subject of or target of any Sanctions and Export Control Laws; (iii) an entity owned, directly or indirectly, individually or in the aggregate, fifty percent or more by one or more Persons described in clause clauses (i) or (ii); or (iv) otherwise engaging in dealings with or for the benefit of any Person described in clauses (i) through – (iii) or any country or territory which is or has, since January 1December 31, 20182017, been the subject of or target of any Sanctions and Export Control Laws (at the time of this Agreement, Russia, Belarus, the Crimea region of Ukraine, Cuba, Iran, North Korea, Venezuela, Sudan and Syria); or (v) otherwise in violation of Sanctions and Export Control Laws. (b) None of Neither the Group Companies, nor any of their respective officers, directors or employees, Companies nor, to the Company’s knowledge, any of their Representatives, Representatives or any other Persons in each case to the extent acting for or on behalf of any of the foregoing has, to the Company’s knowledge, since its applicable date of incorporation, directly or indirectly, Group Companies has (i) made, offered, authorized, facilitated, solicited, promised, paid or received any unlawful contribution, gift, entertainment, bribes, kickbacks, financial kickbacks or other advantage, or anything else of value, regardless of form or amount, similar payments to or from any Person, (ii) made or paid any contributions, directly or indirectly, to a domestic or foreign political party or candidate that violate Anti-Corruption Lawscandidate, or (iii) otherwise made, offered, received, authorized, promised or paid any improper payment prohibited under any Anti-Corruption Laws. (c) There have not been since December 31, 2017, any Proceedings, filings, disclosures, Orders, inquiries or governmental investigations alleging any such violations of Anti-Corruption Laws or (iv) been the subject of any Proceeding or disclosure, or except as otherwise disclosed on Section 3.21(b) of the Company Disclosure Schedule, any internal report or investigation, in each case, regarding any violation or alleged violation under Sanctions and Export Control Laws by the Group Companies or Anti-Corruption Laws, and no such Proceeding is pending any of their Representatives or, to the Company’s knowledge, has any other Persons in each case to the extent acting for or on behalf of any of the Group Companies, and, to the Company’s knowledge, no such Proceedings, filings, disclosures, Orders, inquiries or governmental investigations have been threatenedthreatened or are pending and there are no circumstances likely to give rise to any such Proceedings, filings, disclosures, Orders, inquiries or governmental investigations.

Compliance with International Trade & Anti-Corruption Laws. (a) None Neither the Company nor any of the Group Companies, its Subsidiaries nor their directors or officers nor, to the Company’s knowledge, any of their respective officers, directors or employees, any of their other Representatives, or any other Persons Representatives acting for or on behalf of any of the foregoingtheir behalf, is or has been, since its applicable date of incorporationfor the past three years, (i) a Person named on any Sanctions and Export Control Laws-related list of designated Persons maintained by a Governmental Entity; , (ii) located, organized or resident in a country or territory which is itself the subject of or target of any Sanctions and Export Control Laws; , (iii) an entity owned, directly or indirectly, by one or more Persons described in clause (i) or (ii); , or (iv) otherwise engaging in dealings with or for the benefit of any Person described in clauses (i) through (iii) or any country or territory which is or has, since January 1, 2018or the past three years, been the subject of or target of any Sanctions and Export Control Laws (at the time of this Agreement, Russia, Belarus, the Crimea region of Ukraine, Cuba, Iran, North Korea, Venezuela, Sudan and Syria). (b) None of Neither the Group Companies, Company nor any of their respective officers, directors or employees, its Subsidiaries nor, to the Company’s knowledge, any of their Representatives, or any other Persons respective Representatives acting for or on behalf of any of the foregoing hastheir behalf, to the Company’s knowledge, since its applicable date of incorporation, directly or indirectly, has (i) made, offered, authorized, facilitated, solicited, promised, paid or received any unlawful contribution, gift, entertainment, bribes, kickbacks, financial kickbacks or other advantage, or anything else of value, regardless of form or amount, similar payments to or from any Person, (ii) made or paid any contributions, directly or indirectly, to a domestic or foreign political party or candidate that violate or (iii) otherwise violated any Anti-Corruption Laws, . (iiic) otherwise made, offered, received, authorized, promised or paid any improper payment prohibited under any Anti-Corruption Laws or (iv) been the subject of any Proceeding or disclosure, or except as otherwise disclosed on Section 3.21(b) None of the Company Disclosure ScheduleCompany, any internal report or investigation, in each case, regarding any violation or alleged violation under Sanctions their directors and Export Control Laws or Anti-Corruption Laws, and no such Proceeding is pending officers or, to the Company’s knowledge, any of their other Representatives or any other Persons acting for or on behalf of any of the foregoing has, directly or indirectly, violated any, or been subject to actual or, to the knowledge of the Company, pending or threatened Proceedings, demand letters, settlements or enforcement actions relating to any Anti-Corruption Law. (d) During the last three years, the Company has been threatenedcomplied with all applicable Anti-Corruption Laws.

Compliance with International Trade & Anti-Corruption Laws. (a) None Neither the Company nor any of the Group Companies, its Subsidiaries nor their directors or officers nor, to the Company’s knowledge, any of their respective officers, directors or employees, any of their other Representatives, or any other Persons Representatives acting for or on behalf of any of the foregoingtheir behalf, is or has been, since its applicable date the incorporation of incorporationthe Company, (i) a Person named on any Sanctions and Export Control Laws-related list of designated Persons maintained by a Governmental Entity; , (ii) located, organized or resident in a country or territory which is itself the subject of or target of any Sanctions and Export Control Laws; , (iii) an entity owned, directly or indirectly, by one or more Persons described in clause (i) or (ii); , or (iv) otherwise engaging in dealings with or for the benefit of any Person described in clauses (i) through (iii) or any country or territory which is or has, or since January 1, 2018the incorporation of the Company, been the subject of or target of any Sanctions and Export Control Laws (at the time of this Agreement, Russia, Belarus, the Crimea region of Ukraine, Cuba, Iran, North Korea, Venezuela, Sudan and Syria). (b) None of Neither the Group Companies, Company nor any of their respective officers, directors or employees, its Subsidiaries nor, to the Company’s knowledge, any of their Representatives, or any other Persons respective Representatives acting for or on behalf of any of the foregoing hastheir behalf, to the Company’s knowledge, since its applicable date of incorporation, directly or indirectly, has (i) made, offered, authorized, facilitated, solicited, promised, paid or received any unlawful contribution, gift, entertainment, bribes, kickbacks, financial kickbacks or other advantage, or anything else of value, regardless of form or amount, similar payments to or from any Person, (ii) made or paid any contributions, directly or indirectly, to a domestic or foreign political party or candidate that violate or (iii) otherwise violated any Anti-Corruption Laws, . (iiic) otherwise made, offered, received, authorized, promised or paid any improper payment prohibited under any Anti-Corruption Laws or (iv) been the subject of any Proceeding or disclosure, or except as otherwise disclosed on Section 3.21(b) None of the Company Disclosure ScheduleCompany, any internal report or investigation, in each case, regarding any violation or alleged violation under Sanctions their directors and Export Control Laws or Anti-Corruption Laws, and no such Proceeding is pending officers or, to the Company’s knowledge, any of their other Representatives or any other Persons acting for or on behalf of any of the foregoing has, directly or indirectly, violated any, or been subject to actual or, to the knowledge of the Company, pending or threatened Proceedings, demand letters, settlements or enforcement actions relating to any Anti-Corruption Law. (d) During the last three years, the Company has been threatenedcomplied with all applicable Anti-Corruption Laws.

Compliance with International Trade & Anti-Corruption Laws. (a) None of the Group Companies, northeir directors and officers or, to the Company’s knowledge, any of their respective officers, directors or employees, any of their other Representatives, Representatives or any other Persons acting for or on behalf of any of the foregoing, is or has been, since its applicable date the incorporation of incorporationthe Company, (i) a Person named on any Sanctions and Export Control Laws-related list of designated Persons maintained by a Governmental Entity; (ii) located, organized or resident in a country or territory which is itself the subject of or target of any Sanctions and Export Control Laws; (iii) an entity owned, directly or indirectly, 50% or more by one or more Persons described in clause (i) or (ii); or (iv) otherwise engaging in unlawful dealings with or for the benefit of any Person described in clauses (i) through (iii) or any country or territory which is or has, since January 1, 2018the incorporation of the Company, been the subject of or target of any Sanctions and Export Control Laws (at the time of this Agreement, Russia, Belarus, the Crimea region of Ukraine, Cuba, Iran, North Korea, VenezuelaRussia, Sudan Syria, Venezuela and Syriathe Crimea, Donetsk or Luhansk regions of Ukraine). (b) None of the Group Companies, nor any of their respective officers, directors or employees, norand officers or, to the Company’s knowledge, any of their Representatives, other Representatives or any other Persons acting for or on behalf of any of the foregoing hasforegoing, to the Company’s knowledge, since its applicable date of incorporation, directly or indirectly, has (i) made, offered, authorized, facilitated, solicited, promised, paid or received any unlawful contribution, gift, entertainment, bribes, kickbacks, financial kickbacks or other advantage, or anything else of value, regardless of form or amount, similar payments to or from any Person, (ii) made or paid any improper contributions, directly or indirectly, to a domestic or foreign political party or candidate that violate Anti-Corruption Laws, or (iii) otherwise made, offered, received, authorized, promised or paid any improper payment prohibited under any Anti-Corruption Laws or Laws. (ivc) been the subject of any Proceeding or disclosure, or except as otherwise disclosed on Section 3.21(b) None of the Company Disclosure ScheduleGroup Companies, any internal report or investigation, in each case, regarding any violation or alleged violation under Sanctions their directors and Export Control Laws or Anti-Corruption Laws, and no such Proceeding is pending officers or, to the Company’s knowledge, any of their other Representatives or any other Persons acting for or on behalf of any of the foregoing has, directly or indirectly, violated any, or been subject to actual or, to the knowledge of the Company, pending or threatened Proceedings, demand letters, settlements or enforcement actions relating to any Anti-Corruption Law. (d) During the last five (5) years, the Company has been threatenedcomplied with all applicable Anti-Corruption Laws.

Compliance with International Trade & Anti-Corruption Laws. (a) None of the Group Companies, northeir directors and officers or, to the Company’s knowledge, any of their respective officers, directors or employees, any of their other Representatives, Representatives or any other Persons acting for or on behalf of any of the foregoing, is or has been, since its applicable date the incorporation of incorporationthe Company, (i) a Person named on any Sanctions and Export Control Laws-related list of designated Persons maintained by a Governmental Entity; (ii) located, organized or resident in a country or territory which is itself the subject of or target of any Sanctions and Export Control Laws; (iii) an entity owned, directly or indirectly, by one or more Persons described in clause (i) or (ii); or (iv) otherwise engaging in unlawful dealings with or for the benefit of any Person described in clauses (i) through (iiii)-(iii) or any country or territory which is or has, since January 1, 2018the incorporation of the Company, been the subject of or target of any Sanctions and Export Control Laws (at the time of this Agreement, Russia, Belarus, the Crimea region of Ukraine, Cuba, Iran, North Korea, Venezuela, Sudan Venezuela and Syria). (b) None of the Group Companies, nor any of their respective officers, directors or employees, norand officers or, to the Company’s knowledge, any of their Representatives, other Representatives or any other Persons acting for or on behalf of any of the foregoing hasforegoing, to the Company’s knowledge, since its applicable date of incorporation, directly or indirectly, has (i) made, offered, authorized, facilitated, solicited, promised, paid or received any unlawful contribution, gift, entertainment, bribes, kickbacks, financial kickbacks or other advantage, or anything else of value, regardless of form or amount, similar payments to or from any Person, (ii) made or paid any improper contributions, directly or indirectly, to a domestic or foreign political party or candidate that violate Anti-Corruption Laws, or (iii) otherwise made, offered, received, authorized, promised or paid any improper payment prohibited under any Anti-Corruption Laws or Laws. (ivc) been the subject of any Proceeding or disclosure, or except as otherwise disclosed on Section 3.21(b) None of the Company Disclosure ScheduleGroup Companies, any internal report or investigation, in each case, regarding any violation or alleged violation under Sanctions their directors and Export Control Laws or Anti-Corruption Laws, and no such Proceeding is pending officers or, to the Company’s knowledge, any of their other Representatives or any other Persons acting for or on behalf of any of the foregoing has, directly or indirectly, violated any, or been subject to actual or, to the knowledge of the Company, pending or threatened Proceedings, demand letters, settlements or enforcement actions relating to any Anti-Corruption Law. (d) During the last three years, the Company has been threatenedcomplied with all applicable Anti-Corruption Laws.

Compliance with International Trade & Anti-Corruption Laws. (a) None of Neither the Group Companies, Companies nor, to the Company’s knowledge, any of their respective officers, directors or employees, any of their other Representatives, or any other Persons acting for or on behalf of any of the foregoing, is or has been, since its applicable date of incorporationin the last five (5) years, (i) a Person named on any Sanctions and Export Control Laws-related list of designated Persons maintained by a Governmental Entity; (ii) located, organized or resident in a country or territory which is itself the subject of or target of any Sanctions and Export Control Laws; (iii) an entity ownedowned in any part, directly or indirectly, by one or more Persons described in clause (i) or (ii); or (iv) otherwise engaging in dealings with or for the benefit of any Person described in clauses (i) through (iii) or any country or territory which is or has, since January 1, 2018in the last five (5) years, been the subject of or target of any Sanctions and Export Control Laws (at the time of this Agreement, Russia, Belarus, the Crimea region of Ukraine, Cuba, Iran, North Korea, Venezuela, Sudan Venezuela and Syria). (b) None In the last five (5) years, none of the Group CompaniesCompanies have received from any Governmental Entity or any other Person any notice, nor inquiry, or internal or external allegation, made any of their respective officersvoluntary or involuntary disclosure to a Governmental Entity, directors or employeesconducted any internal investigation or audit concerning any actual or potential violation or wrongdoing, in each case, related to, or in connection with Sanctions and Export Control Laws. (c) Neither the Group Companies nor, to the Company’s knowledge, any of their Representatives, or any other Persons acting for or on behalf of any of the foregoing has, to the Company’s knowledge, since its applicable date of incorporation, directly or indirectly, has (i) made, offered, authorized, facilitated, solicited, promised, paid or received any unlawful contribution, gift, entertainment, bribes, kickbacks, financial kickbacks or other advantage, or anything else of value, regardless of form or amount, similar payments to or from any Person, (ii) made or paid any contributions, directly or indirectly, to a domestic or foreign political party or candidate that violate Anti-Corruption Laws, Laws or (iii) otherwise made, offered, received, authorized, promised or paid any improper payment prohibited under any Anti-Corruption Laws. (d) The Group Companies have adopted a system of policies, procedures, and internal controls to the extent required by applicable Anti-Corruption Laws or (iv) been the subject and any such policies, procedures and internal controls are reasonably designed to prevent violations of any Proceeding or disclosure, or except as otherwise disclosed on Section 3.21(b) of the Company Disclosure Schedule, any internal report or investigation, in each case, regarding any violation or alleged violation under Sanctions and Export Control Laws or such Anti-Corruption Laws, and no such Proceeding is pending or, to the Company’s knowledge, has been threatened.

Compliance with International Trade & Anti-Corruption Laws. (a) None of the Group Companies, nor, to the Company’s knowledge, any of their respective officers, directors or employeesemployees or, to the Company’s knowledge, any of their other Representatives, or any other Persons acting for or on behalf of any of the foregoing, is or has been, since its applicable date of incorporationin the prior three years, (i) a Person named on any Sanctions and Export Control Laws-related list of designated Persons maintained by a Governmental Entity; (ii) located, organized or resident in a country or territory which is itself the subject of or target of any Sanctions and Export Control Laws; (iii) an entity owned, directly or indirectly, by one or more Persons described in clause (i) or (ii); or (iv) otherwise engaging in dealings with or for the benefit of any Person described in clauses (i) through (iii) or any country or territory which is or has, since January 1, 2018in the prior three years, been the subject of or target of any Sanctions and Export Control Laws (at the time of this Agreement, Russia, Belarus, the Crimea region of Ukraine, Cuba, Iran, North Korea, Venezuela, Sudan and Syria). (b) None of the Group Companies, nor any of their respective officers, directors or employees, noremployees or, to the Company’s knowledge, any of their other Representatives, or any other Persons acting for or on behalf of any of the foregoing has, to the Company’s knowledge, since its applicable date of incorporation, directly or indirectly, has (i) made, offered, authorized, facilitated, solicited, promised, paid or received any unlawful contribution, gift, entertainment, bribes, kickbacks, financial kickbacks or other advantage, or anything else of value, regardless of form or amount, similar payments to or from any Person, (ii) made or paid any contributions, directly or indirectly, to a domestic or foreign political party or candidate that violate Anti-Corruption Laws, or (iii) otherwise made, offered, received, authorized, promised or paid any improper payment prohibited under any Anti-Corruption Laws or Laws. (ivc) been the subject of any Proceeding or disclosure, or except as otherwise disclosed on Section 3.21(b) of the Company Disclosure Schedule, any internal report or investigation, in each case, regarding any violation or alleged violation under Sanctions and Export Control Laws or Anti-Corruption Laws, and no such Proceeding is pending or, to To the Company’s knowledge, has been threatenedas of the date hereof, there are no current or pending internal investigations, third-party investigations (including by any Governmental Entity), or internal or external audits that address any material allegations or information concerning possible material violations of the Anti-Corruption Laws related to the Company or any of the Company’s Subsidiaries.