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 EnTrust Entities, nor any of their directors, officers or employees or, to the Knowledge of the EnTrust Contributor, their agents (including placement agents), Affiliates or representatives, or any other Person in respect of any actions for or on behalf of any EnTrust Entity, has been or is the subject of any past, current, pending or threatened investigation, inquiry or enforcement proceedings for violations of any applicable Anti-Bribery Laws, Sanctions Laws or Trade Control Laws by any Governmental Authority in any country in which any such EnTrust Entity or its Subsidiaries does business, including any United States Governmental agency for any alleged violation of the Foreign Corrupt Practices Act of 1977, as amended, or any U.K. Governmental agency for any alleged violation of the U.K. Bribery Act of 2010.