All Bridgewell employees are responsible for following the company’s Foreign Corrupt Practices Policy and attending annual training on this topic.

It is the policy of Bridgewell Resources not to make, directly or through an agent or otherwise, any payment, gift, or anything else of value (or any offer or promise of such a payment or gift) to any foreign official, if the purpose is to have a foreign official act contrary to the obligations of his or her position.

For purposes of this policy, a “foreign official” includes any officer or employee of any foreign government, instrumentality, or agency, or public international organizations, or anyone acting in an official capacity. It may also include officers and employees of state-owned businesses.

Payments or gifts to such foreign officials are prohibited, where the purpose is:

(a) to influence any act or decision of an official in his or her official capacity;

(b) to induce such official to do or omit to do any act in violation of his or her lawful duty;

(c) to induce such official to use his or her influence with the government in order to obtain or retain business, or to direct business, or

(d) to secure any improper advantage for Bridgewell Resources.

In addition, there should be no payments or gifts made, or offer or promise as to payments or gifts, directly or indirectly, to any foreign political party, any official of any such foreign political party, or any candidate for foreign political office.