Gifts and Entertainment Policy

The Gifts and Entertainment Policy sets forth minimum standards related to the provision or receipt of gifts and entertainment by the Company’s employees. Employees are required to comply with this policy as well as any applicable divisional, regional or local policies concerning gifts and entertainment and/ or any business expense limits imposed on gift and entertainment expenditures. The divisional, regional or local policies may set forth more stringent standards than this policy.

Employees are required to comply with the more stringent standard that applies to them.

Where employees have questions related to providing or receiving a gift and/or entertainment, they should contact their direct supervisor or line manager (collectively “Supervisor”) and local Legal Department (“LD”) professional prior to incurring the expense, accepting the gift or entertainment, or otherwise committing the Company (e.g., before sending invitations or contracting with host locations). Failure to comply with this policy may result in criminal, civil and regulatory penalties for the Company and the employee, as well as internal disciplinary action for the employee (including termination of employment).