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b. Dealing with Government Officials and Lobbying Activities

EXP and its employees comply with all laws that regulate our contacts with government officials at federal, state, provincial or municipal levels in every jurisdiction where the Company operates. In United States and Canada, public officials include broad range of civil servants including any employees of government-owned and controlled cor- porate entities. To ensure compliance with all lobbying laws, contact must be made with the EXP Legal Department before engaging with government officials at the federal, provincial, state and local level.

For more information on dealing with government officials, please refer to EXP’s Anti-Corruption Policy.

c. Political Activities and Contributions

Subject to applicable laws, employees are encouraged to participate in the political process and to support candi- dates and causes of their choice, as long as such activities are carried out on your own time and without using EXP’s property. Any political views expressed by you must be clearly identified as your own views – and not those of EXP.

EXP and its employees abide by all laws and regulations governing political contributions in every jurisdiction where the Company operates.

d. Charitable Donation

We support community development and humanitarian and charitable endeavors throughout the world. Our em- ployees are encouraged to contribute to these efforts. However, as with political activities, you may not use Com- pany resources to personally support charitable or other non-profit institutions without Company’s prior written authorization. You should consult the Legal Department if you have questions about permissible use of Company resources.

e. Gifts and Entertainment

Business gifts and entertainment are “courtesies” designed to build working relationships with our suppliers and clients. Giving or receiving anything of value is not permitted if it creates an obligation, puts the employee in a sit- uation where EXP appears to be biased, or influences EXP’s, or our clients’, business decisions. While at times it may appear customary to accept or provide gifts or entertainment, laws governing the exchange of business courtesies vary from country to country, may require disclosure to either a corporate or government entity and may result in penalties for violating these laws or requirements. It is EXP’s policy that employees will not, except in rare circumstances or where custom dictates, solicit or accept gifts, favors, loans, gratuities, rewards, promises of future employment, or any other things of value, including travel or lodging. It is also our policy that, except in rare circumstances or where custom dictates, we do not offer gifts or entertainment to clients to influence business decisions. When offering gifts, entertainment, meals or anything of value, employees should be guided by good judgment, discretion, moderation and transparency. All gifts given or received will be reported to and recorded by the EXP finance department and reported in accordance with any tax or regulatory requirements.

CODE OF ETHICS + BUSINESS CONDUCT | Revised 2020.08