October 31, 2005

Anti-Bribery Compliance Program Policy

This sample outlines a set of policies and procedures to prevent violation of any and all national and international anti-bribery and anti-corruption laws and treaties. All employees, agents of the Company, joint-venture partners, or anyone else doing business in Company X’s name, are required to comply strictly with the FCPA, all other applicable anti-bribery and anti-corruption treaties, and all national laws.