I.C. Intelligence (“ICI”) maintains an Anti-Bribery and Corruption (“ABC”) Policy prohibiting any improper or unethical payment to government officials or a party to a private commercial transaction anywhere in the world by any ICI officer or associate (together, simply “ICI Associates”) or Agent of ICI. This ABC Policy is designed to comply with the requirements of the U.S. Foreign Corrupt Practices Act (the “FCPA”), the U.K. Bribery Act 2010 (the “U.K. Bribery Act”) and the anti-bribery laws of those other jurisdictions in which we do or may do business. These laws generally prohibit bribes, kickbacks, or illegal payments to influence business transactions and require ICI to maintain accurate books and records and a system of internal controls.