To avoid potential liability for the conduct of international representatives, consultants, agents, or other third parties who interact with foreign government officials on the Company’s behalf (collectively “Intermediaries”), it is the Company’s policy to investigate the background and reputation of its prospective Intermediaries to give it a factual basis for concluding that the Intermediary will do so in a manner that fully complies with applicable laws and the Company’s Code of Ethics. This “due diligence’’ must take place before the Intermediary is retained and must be updated when extending or renewing an Intermediary’s contract.