Ethics and Compliance Policies and Procedures (E&C Policies) are developed to address certain areas of legal or regulatory compliance risk. There are some aspects of the Company's Code of Conduct that are also expanded upon in E&C Policies.

The E&C Policies are provided to facility Ethics and Compliance Officers for notice and distribution within each facility; are posted on the Company's intranet; and are posted on the Company's external website. Individuals within a facility who have responsibility for a particular area of compliance risk addressed by policy are responsible for implementing relevant policies, conducting necessary monitoring and overseeing corrective action or process improvements.

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