Common use of Sanctions and Export Controls Clause in Contracts

Sanctions and Export Controls. Since its inception, the Company has not, and since January 1, 2015, none of its Subsidiaries or, to the knowledge of the Company, any director, officer, employee or agent of the Company or any of its Subsidiaries, (a) is or was a Sanctioned Person, (b) has conducted business, directly or indirectly, with any Sanctioned Person or in any Sanctioned Country on behalf of the Company or any of its Subsidiaries, except as authorized by the applicable government authority, or (c) has violated or engaged in any conduct prohibited under any applicable Sanctions Laws or Export Controls. The Company and each of its Subsidiaries has instituted and maintains a system of internal controls designed to provide reasonable assurance that violations of applicable Anti-Corruption Laws, Sanctions Laws, and Export Controls will be prevented, detected, and deterred.

Sanctions and Export Controls. Since its inception, the Company has not, and since January 1, 2015, none of the Company or its Subsidiaries or, to the knowledge of the Company’s Knowledge, any director, officer, employee or agent of the Company or any of its Subsidiaries, (ai) is or was a Sanctioned Person, (bii) has conducted business, directly or indirectly, with any Sanctioned Person or in any Sanctioned Country on behalf of the Company or any of its Subsidiaries, except as authorized by the applicable government authority, or (ciii) has violated or engaged in any conduct prohibited sanctionable under any applicable Sanctions Laws or Export Controls. The Company and each of its Subsidiaries has instituted and maintains a system of internal controls designed to provide reasonable assurance that violations of applicable Anti-Corruption Laws, Sanctions Laws, and Export Controls will be prevented, detected, and deterred.