Global Trade and Compliance, LLC

Foreign Corrupt Practices Act (FCPA) Statement

Global Trade & Compliance, LLC (“GTAC”) will comply fully at all times with applicable national and international anti-bribery laws, including, without limitation, the U.S. Foreign Corrupt Practices Act, the U.K. Bribery Act and applicable EU, OECD and Council of Europe anti-bribery rules. GTAC will not offer, make, promise to make, or authorize the making of any gift or payment of money or anything of value either directly or indirectly for purposes of (a) influencing any act or decision of any government official or political party (or candidate thereof) (collectively, “Officials”); (b) inducing an Official to do or omit to do any act in violation of the lawful duty of that Official; or (c) inducing an Official to use influence with a non-U.S. government or instrumentality to facilitate GTAC’s performance of its obligations.