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6. Fair Competition

a. Anti-Trust and Competition Laws

Anti-trust and competition laws generally prohibit agreements between competitors such as bid-rigging, inap- propriate information sharing, price-fixing, and market, customer or territory allocations. EXP and its employ- ees do not participate in discussions with representatives of a competitor that appear to be about these issues or about how we can work in concert to set prices, divide markets or manipulate business opportunities. Should you become aware of, or be asked to participate in, a discussion of this nature, employees must imme- diately contact the EXP Legal Department. EXP competes ethically on its merits and in so doing, deals honestly and fairly with our clients, competitors and suppliers. We only seek information about our clients and competitors from publicly available and legal sources of information. Our competitive information is confidential and we do not provide it to anyone outside of the Company; and only to those other EXP employees who have a “need-to-know”. We do not ask co-workers to reveal information about former employers, clients or business partners if this disclosure would violate obligations of confidentiality. If an employee possesses competitive information from a prior employer, they must not disclose it to EXP or its employees if this disclosure violates confidential- ity obligations owed to others. 7. Waivers The Company strongly discourages management from waiving any aspect of the Code for any employee. EXP’s Board of Directors must be apprised of any such waiver. Moreover, only the EXP Board of Directors may waive any element of the Code for Officers and Directors, and any such waiver must be properly disclosed to shareholders, to the extent required by law, regulation or stock exchange requirement. In addition, all waivers must be in writing. 8. Reporting Violations b. Competitive Information

a. Ethics Line

Employees are obligated to report any violation of this Code to their supervisor or to a Company department referenced in the Code.

CODE OF ETHICS + BUSINESS CONDUCT | Revised 2020.08