Anti-corruption Policy

ANTI-CORRUPTION POLICY BASED ON THE FOREIGN CORRUPT PRACTICES ACT (FCPA) OF THE UNITED STATES OF AMERICA.

Objective and implementation:

We expect all Perspective staff to perform their activities in a legal and ethical manner, as indicated in the Perspective code of conduct. Improper gifts, payments or offers of any value to foreign officials could jeopardize both Perspective ongoing business and reputation. The use of company funds or financial assets for improper illegal or unethical purposes is also prohibited. Specifically, it is Perspective policy to fully comply with the standards set forth in the FCPA.

Forbidden Payments:

The FCPA bribery provisions prohibit bribing foreign officials in order to retain or secure a business or any other advantage. Specifically, the FCPA prohibits making payments, offering or giving money or anything of value to any foreign official for the purpose of corrupting them.

Under this policy, the term “Foreign Official” refers to both officials or employees of a foreign government or those of public international organizations. The term foreign official includes not only elected officials but also advisors with government positions, employees of companies owned by foreign governments, political party officials and others. The FCPA prohibits both direct and indirect payment to foreign officials.

Therefore, pursuant to the FCPA an American company will be responsible for the undue payment made by both its agents or other business partners. Perspective staff must not make or authorize gifts, payments or offers of any value to foreign officials, whether local, regional or national, except as provided in these regulations.

Examples of measures to obtain or retain business:

• Award of a contract
• Influence the acquisition process
• Avoid product import regulations
• Access to tenders and bidding processes that are not public
• Evasion of taxes or fines
• Influence the verdict of a suit or its enforcement
• Obtain exemptions from the regulations
• Bypass the termination of a contract.

Records management, accounting and payment practices:

The FCPA records management provisions require that company books, records and accounts reflect correctly and in reasonable detail transactions and dispositions of assets. Therefore, the FCPA prohibits the mischaracterization or omission of any transaction in the company's books.

Before paying or authorizing a payment to a foreign official, Perspective employees or representatives must be certain that the payment will not be made for any other purpose than that described exactly and in full in Perspective books and records. Therefore, the following practices are prohibited:

The opening of secret or unregistered accounts

False or artificial entries in books and records

The use of personal funds to do anything that is somehow prohibited by Perspective policy.

Due diligence and selection of representatives and business partners

Perspective will participate fairly and ethically in all business opportunities and negotiate contracts fairly and openly regardless of any pressure exerted by foreign officials.