FCPA Update & Overview

2. Anti-Corruption History

7. U.S. Cases Brought

11. Number of FCPA Proceedings by Country South America North America Middle East Europe Asia Africa 33 8 39 17 75 43 1 Uzbekistan 1 Turkmenistan 1 Mongolia 1 Nicaragua 2 Russia 1 Bolivia 1 Spain 2 Philippines 2 Venezuela 1 Poland 2 Bangladesh 2 Dom. Rep. 1 Luxemburg 3 Taiwan 3 Jamaica 2 Israel 1 Italy 5 Thailand 1 Liberia 3 Ecuador 2 Iran 1 Greece 6 South Korea 2 Kenya 3 Colombia 2 Bahrain 1 Belgium 6 Kazakhstan 2 Angola 3 Argentina 4 UAE 2 UK 7 Azerbaijan 3 Benin 4 Panama 4 Saudi Arabia 2 France 8 India 4 Senegal 5 Brazil 2 Mexico 6 Egypt 3 Germany 14 Indonesia 6 Rwanda 6 Costa Rica 6 Canada 19 Iraq 4 Turkey 17 China 25 Nigeria

12. U.S. Criminal Dispositions Compliance Monitor 16% (16) Deferred/Non-Prosecution Agreements 21% (23) Pleas 44% (48) Withdrawals 1% (1) Convictions 4% (5) Dismissals 3% (3) Fugitives 5% (6) Acquittals 6% (7)

24. RED FLAGS: Agent/Vendor I Agent/Vendor Related to customer or government official Questionable past Incorporated in high risk country Primary strength is influence Lacks experience Lacks references Government official referred Was referred by customer Commercial capability Established facilities Experience in the region Favorable business references No government contracts Based in low risk country Commercial directory listings Past relationship with company

25. RED FLAGS: Agent/Vendor II Agent/Vendor Anonymity Refuses corruption contract provisions Misleading payment structure False documents Subcontracting to third party Excessive compensation Success fee Transparent payment process Accurate documentation Detailed scope of work Concrete deliverables Effort-based compensation On-budget, on-time performance Interface with qualified staff

26. RED FLAGS: Payments Payment Third countries or parties Shell companies Post office boxes Unexpected bonuses or loans Requests negotiable currency Larger payments during bid process Third country banks Invoices paid too quickly Established banks Matches commercial capability Regular channels Commercially reasonable terms Reasonable compensation Payment in country

27. RED FLAGS: Operations Operations Requests backdating or fraudulent documentation Connection with government or customer emerges Suspicious documentation Becomes subject to investigation Suspicious expenses or travel Refuses to certify compliance Well-trained employees Anti-corruption program Accurate documentation Performance consistent with proposals