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 for a corrupt purpose.

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, or any foreign political party, any official of a foreign political party, or any candidate for foreign political office. It may also include officers and employees of state-owned businesses.

Payments or gifts to such foreign officials are prohibited, where the purpose is to assist Bridgewell Resources in obtaining or retaining business or to direct business to any person, in addition any one or more of the following corrupt purposes:

(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 secure an improper advantage; or

(d) to induce such official to use his or her influence with the government in order to affect or influence a decision of that government.

In addition, there should be no payments or gifts made, or offer or promise as to payments or gifts, directly or indirectly, when an employee knows that all or a portion of such payment, gift, offer, or promise will be made to a foreign official for any of the corrupt purposes listed above.