Service Provider:

Represents and agrees that it shall be bound by and abide to all laws and regulations as well as strictly comply with both the letter and spirit of the OECD Convention on Combating Bribery of Foreign Public Officials, the UK Bribery Act, the U.S. Foreign Corrupt Practices Act (“FCPA”), and any other applicable anti-corruption and anti-money laundering laws.

Agrees, undertakes and confirms that neither it, nor its directors, officers, employees, agents or service providers have paid, offered, promised or authorized, or will pay, promise to pay, authorize to pay money or transfer, offer or promise anything of value including, without limitation, gifts or entertainment or Facilitation Payments to a person in a position of trust in order to obtain, influence, induce or reward any improper advantage in connection with Pro Carrier business. A person in a position of trust includes any public official, political candidate, political party, party official and private sector employee or individual.

Subject to any relevant data privacy or protection law, Service Provider shall immediately report to Pro Carrier:

Any request or demand received by Service Provider, or any other party engaged by Service Provider, that could amount to a breach of the AntiCorruption Laws or Anti-Corruption Obligation, or

Any allegations, proceedings or investigations relating to bribery, corruption or money laundering against Service Provider, its directors, officers, employees or its service providers engaged in connection with Pro Carrier business.

Undertakes to:

Maintain at its normal place of business, throughout the term of Service Provider’s business relationship with Pro Carrier and for at least 6 (six) years following its expiration or termination, detailed books, records and accounts which accurately and fairly reflect all transactions and payments made by Service Provider in connection with the above business relationship;

Maintain an internal accounting controls system that is sufficient to ensure proper authorization, recording and reporting of all transactions and payments made by Service Provider and is sufficient to ensure, and enable Pro Carrier to verify the Service Provider’s compliance with Anti-Corruption Laws and the AntiCorruption Obligation.

Agrees that, within validity period of the contract between Service Provider and Pro Carrier and for a period ending 6 (six) years thereafter, upon request, Pro Carrier shall have the right at their own expense to inspect and audit at all reasonable times, and take copies of any of Service Provider’s records, including data stored on computers, books, records, accounts, correspondence, memoranda, receipts, vouchers and other papers of every kind in connection with Service Provider’s work and all transactions related thereto as may be necessary in the opinion of Pro Carrier to verify Service Provider’s compliance with Anti-Corruption Laws and/or the Anti-Corruption Obligation. Service Provider shall cooperate fully with Pro Carrier in the carrying out of any audit required by Pro Carrier. DocuSign Envelope ID: E49240A5-F133-416D-BA73-C0CB1620E44D Anti-Corruption Obligation

In addition, Service Provider shall cooperate and provide all reasonable assistance, including making its books, records, accounts and personnel available, to enable both Pro Carrier to investigate any actual or potential breach of, or perform any activity required by any relevant government or agency in connection with ensuring or verifying Service Provider’s compliance with Anti-Corruption Laws and/or the Anti-Corruption Obligation. These rights shall continue for 6 (six) years after termination or expiration of Service Provider’s business relationship with Pro Carrier and will be exercised in compliance with all applicable competition laws. Pro Carrier shall use all reasonable endeavors to conduct any such inspections and audits in a manner which shall result in a minimum of inconvenience to Service Provider.

Represents and warrants that except as otherwise disclosed in writing to Pro Carrier, throughout the term of Service Provider’s business relationship with Pro Carrier:

none of Service Provider’s directors, officers, employees or other service providers used for Pro Carrier business is a Public Official; and

no Public Official has and will have a direct or indirect interest in Service Provider, has or will have any legal or beneficial interest in any payments made by Pro Carrier to Service Provider; and

it will promptly notify Pro Carrier in writing of any change in the foregoing.

Represents and warrants that except as otherwise disclosed in writing to Pro Carrier, neither Service Provider nor its directors, officers, or key employees in connection with Pro Carrier's business have in the last 10 (ten) years:

been convicted of any offence involving bribery, corruption or money laundering; or

been or are the subject of any investigation, inquiry or enforcement proceedings by any governmental, administrative or regulatory body regarding any offence or alleged offence involving bribery, corruption or money laundering.

Agrees and warrants that any information supplied or communicated by Pro Carrier otherwise acquired by Service Provider in connection with the business with Pro Carrier shall be treated by Service Provider as confidential and shall not, without prior approval, be published or disclosed, or made use of, reproduced or copied by Service Provider except to the extent necessary for the purpose of performing Service Provider’s contractual obligations. Service Provider shall ensure that the Service Provider’s affiliates, directors, officers, employees, agents and service providers comply with the same confidentiality provisions. Service Provider shall use reasonable efforts that the above confidentiality provisions are incorporated in any other subcontracts, and to the extent incorporated, that the affiliates, directors, officers, employees and agents of such subcontractors comply with the same. In the event Pro Carrier reasonably believes in good faith that Service Provider has failed to comply with or breached in any respect any of the requirements set out in this Anti-Corruption Obligation, Pro Carrier may arrange suspension of all further services and payments related thereto, and/or termination of any contractual arrangements with Service Provider, in whole or in part with immediate effect.