Through our Principles of Business Conduct, we have various mechanisms that encourage employees to report concerns of improper business conduct, which would include allegations of corruption.

Our normal process, when learning of such an allegation, is to review the facts and circumstances and determine what kind of investigation is appropriate. Upon completion of the investigation, we take action against the employee, vendor or other associated party, if appropriate, and we also review our policies and procedures to determine how and whether we can improve our procedures to prevent a similar issue from occurring in the future.  We also have established communication between our business unit compliance officers and our corporate compliance group related to potential incidents of corruption and other serious investigations.