Anti-Bribery. Provider has not and will not directly or indirectly offer or pay, or authorize such offer or payment, of any money or anything of value or improperly seek to influence any Government Official. For purposes of this Section, a “Government Official” is broadly defined as and includes: # any elected or appointed government official (e.g., a member of a ministry of health) and # any employee or person acting for or on behalf of a government official, agency, or enterprise performing a governmental function; where “government” is meant to include all levels and subdivisions of non-US governments (i.e., local, regional, or national and administrative, legislative or executive).

Anti-Bribery; Anti-Corruption. Neither Holdings nor any of its Subsidiaries, nor any director or officer of Holdings or its Subsidiaries, nor, to the knowledge of Holdings and the Borrower, any agent, employee or representative of Holdings or its Subsidiaries, or any affiliate or other person associated with or acting on behalf of Holdings or its Subsidiaries, has # used any corporate funds for any unlawful contribution, gift, entertainment or other unlawful expense relating to political activity; # made or taken an act in furtherance of an offer, promise or authorization of any direct or indirect unlawful payment of corporate funds or benefit to any foreign or domestic government or regulatory official or employee, including, without limitation, of any government-owned or controlled entity or of a public international organization, or any person acting in an official capacity for or on behalf of any of the foregoing, or any political party or party official or candidate for political office; # violated or is in violation of any provision of the U.S. Foreign Corrupt Practices Act of 1977, as amended, the U.K. Bribery Act 2010, as amended, the Corruption of Foreign Public Officials Act (Canada), as amended, or any applicable law or regulation implementing the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, or committed an offense under any other applicable anti-bribery or anti-corruption laws; or # made, offered, agreed, requested or taken an act in furtherance of any unlawful bribe or other unlawful benefit, including, without limitation, any rebate, payoff, influence payment, kickback or other unlawful or improper payment or benefit. Each of Holdings and the Borrower has instituted, maintained and enforced, and will continue to maintain and enforce, policies and procedures designed to promote and ensure compliance with all applicable anti-bribery and anti-corruption laws.

None of the EnTrust Entities, nor any of their directors, officers or employees or, to the Knowledge of the EnTrust Contributor, their agents (including placement agents), Affiliates, representatives or any other Person while acting for or on behalf of any EnTrust Entity, has in the past five (5) years, directly or indirectly, # made or reimbursed any contribution, gift, bribe, payoff, influence payment, kickback, rebate, commission, travel or entertainment expense, or other unlawful payment to any Person, private or public, regardless of form, whether in money, property, or services in violation of any applicable Law, # established, maintained or expended any fund or asset with respect to any EnTrust Entity that has been improperly or inaccurately recorded in the books and records of the EnTrust Entities in violation of any applicable Law, # knowingly offered, promised, made or received any payment or anything of value to or from any Person in violation of the Foreign Corrupt Practices Act of 1977, as amended, the U.K. Bribery Act 2010, or any applicable Law enacted in any applicable jurisdiction in connection with, or arising under the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, signed December 17, 1997, or any similar applicable laws, rules, or regulations issued, administered or enforced by a Government Authority or # violated any state or federal “pay to play” Laws, ethics or similar disclosure Laws or lobbyist registration Laws (collectively, the “Anti-Bribery Laws”).

None of the Permal Entities, nor any of their directors, officers or employees or, to the Knowledge of the Permal Contributor, their agents (including placement agents), Affiliates, representatives or any other Person while acting for or on behalf of any Permal Entity, has in the past five (5) years, directly or indirectly, # made or reimbursed any contribution, gift, bribe, payoff, influence payment, kickback, rebate, commission, travel or entertainment expense, or other unlawful payment to any Person, private or public, regardless of form, whether in money, property, or services in violation of any applicable Law, # established, maintained or expended any fund or asset with respect to any Permal Entity that has been improperly or inaccurately recorded in the books and records of the Permal Entities in violation of any applicable Law, # knowingly offered, promised, made or received any payment or anything of value to or from any Person in violation of the Foreign Corrupt Practices Act of 1977, as amended, the U.K. Bribery Act 2010, or any applicable Law enacted in any applicable jurisdiction in connection with, or arising under the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, signed December 17, 1997, or any similar applicable laws, rules, or regulations issued, administered or enforced by a Government Authority or # except as set forth in [Section 5.12(i)(i)(D)] of the Permal Disclosure Schedule, violated any state or federal “pay to play” Laws, ethics or similar disclosure Laws or lobbyist registration Laws.

Anti-Corruption and Anti-Bribery Laws. Neither the Company nor any of its subsidiaries nor any director, officer, or employee of the Company or any of its subsidiaries, nor to the knowledge of the Company or any of its subsidiaries, any agent, affiliate or other person acting on behalf of the Company or any of its subsidiaries has, in the course of its actions for, or on behalf of, the Company or any of its subsidiaries # used any corporate funds for any unlawful contribution, gift, entertainment or other unlawful expenses relating to political activity; or # violated or is in violation of any provision of the U.S. Foreign Corrupt Practices Act of 1977, as amended (the “FCPA”), the UK Bribery Act 2010, or any other applicable anti-bribery or anti-corruption law. The Company and its subsidiaries and, to the knowledge of the Company and each of its subsidiaries, the Company’s affiliates have conducted their respective businesses in compliance with the FCPA.

“Anti-Corruption Laws” means the # United States Foreign Corrupt Practices Act of 1977, as amended, # the United Kingdom Bribery Act of 2010 and any applicable anti-bribery or anti-corruption related provisions and/or anti-bribery, and corruption and/or anti-money laundering laws of any jurisdiction in which a Borrower conducts business.

“Anti-Corruption and AML Laws” means all laws, rules, and regulations, as amended, concerning or relating to money laundering, bribery or corruption, including, without limitation, the U.S. Foreign Corrupt Practices Act of 1977, and all other applicable anti-bribery, anti-money laundering and corruption laws.

“Anti-Corruption Laws” shall mean all laws, rules and regulations of any jurisdiction applicable to the Borrower or its Subsidiaries concerning or relating to bribery or anti-corruption.

“Anti-Corruption Laws” means any Laws of any Governmental Authority concerning or relating to bribery or corruption.

Section # Anti-Corruption and Anti-Money Laundering Laws. Conduct its businesses in compliance with the United States Foreign Corrupt Practices Act of 1977, the UK Bribery Act 2010, and other similar anti-corruption or anti-money laundering legislation in other jurisdictions, and maintain policies and procedures designed to promote and achieve compliance with such laws.