code-of-conduct-final-EN-PL-4

INTRODUCTION + BUSINESS INTEGRITY | 7

If you have questions, need guidance or have reasonable grounds to believe a provision of the Code has been breached, or that you may have breached the Code, you should promptly speak to one of the following persons:

• Your supervisor • Vice-President of Human Resources • General Counsel, Legal Department • You may also report your issue to our confidential Ethics Line at 1-866-489-5803 or www.reportlineweb.com/EXP.

2. Business Integrity

EXP is committed to conduct itself with integrity in all its business transactions and relationships wherever it operates. It takes zero-tolerance approach to all forms of corru ption.

Given the nature of the international services EXP provides, the Company and its employees comply with all local anti-cor- ruption and procurement integrity laws as well as domestic laws such as the Corruption of Foreign Public Officials Act (Canada) and the Foreign Corrupt Practices Act (United States), including any internal compliance programs related to these laws. The penalties for violation of the applicable laws can include fines and even imprisonment. Further, any sanctions un- der these applicable laws will result in serious reputational damage for EXP and may even result in disqualification of EXP for certain government contracts.

Any non-compliance or failure to respect the letter or spirit of this provision of the Code or the applicable laws will also result in immediate disciplinary measures including termination of employment.

a. Bribery and Kickbacks

All forms of corruption including bribery, kickbacks or facilitation payments are strictly prohibited. Neither EXP nor our employees offer or receive bribes and kickbacks.

To ensure compliance with the illegal payments provision of the FCPA and other applicable laws, EXP prohibits use of agents acting on behalf of EXP to secure work in return for contingent fee on successful contract awards. Any lo- cal representative, consultants or independent contractor retained for consulting services or any local joint venture or consortium partner must be approved by the EXP Legal Department and agree to comply with our Code and EXP’s Anti-Corruption Policy.

Whenever you are in a situation where you are asked for, or there is an implication that you must provide, some compensation in exchange for work, you must immediately contact the EXP Legal Department.