Anti-Bribery Policy - EthicsPoint

Anti-BriberyStatement of PolicyPolicy # CMP-2-15 Issued By: Corporate Compliance Page: 4 of 6Avoiding labor, immigration, health, safety or environmental fines or penaltiesImproperly obtaining permits or licensesTherefore, the following are prohibited activities:Giving cash or a cash equivalent (such as gift cards).Providing excessive or lavish meals, entertainment, travel or lodging. For further guidance onproviding meals, entertainment, travel or lodging as part of business development activities,refer to the Travel and Entertainment Policy.Providing expensive gifts to a Domestic or Foreign Government Official or private businessperson that is excessive. It should be noted that many government officials are forbidden bylaw from accepting gifts, so providing gifts, other than items that include the Company logo, isdiscouraged. For more information on gifts, refer to the Gift Policy and the FCPA CompliancePolicy and Procedures.Charitable donations, sponsorships, or trade association or professional memberships that arerequested by a Domestic or Foreign Government Official or private business person and thatare given or promised only as an inducement to provide the Company with an unfair businessadvantage.6.1.1 Engaging Third Party IntermediariesThe Company prohibits Employees from engaging vendors or Third Party Intermediaries when theEmployee knows or has reason to believe that any part of the payment will be used to influence aprivate business person or a Domestic or Foreign Government Official to gain an unfair businessadvantage. In other words, Layne does not hire vendors or Third Party Intermediaries to engage in anyof the prohibited activities listed in Section 6.1 above.All Third Party Intermediaries in international locations must be pre-approved by the Compliance Team.Refer to the FCPA Compliance Policy and Procedures for more information.6.1.2 Applicable LawsEmployees must abide by all applicable domestic and international anti-bribery laws, including, but notlimited to:Commercial Bribery Laws – Commercial bribery is a bribe to a private business person,including a bribe to obtain or retain business with a private client or customer.Domestic Bribery Laws – Domestic bribery is a bribe to a Government Official within theUnited States. U.S. Foreign Corrupt Practices Act (the "FCPA") – Considering the heightened risk ofcorruption in some of the countries in which Layne does business and in order to fully complywith the FCPA, Layne has issued an FCPA Compliance Policy and Procedure. The FCPACompliance Policy and Procedure contains instructions and guidance for Employees regardinghigh risk interactions with Foreign Government Officials that must be monitored by theCompliance Team. The FCPA Compliance Policy and Procedure must be read and understoodby any Employee who is either working in an international location or has any responsibility orbusiness connection to Layne’s international operations.