COMSAT, Inc. is committed to conducting all business with integrity and to comply with all applicable laws, both in letter and in spirit. Our strict codes of business conduct offer all employees a framework for ensuring that we are operating in a way that places ethical business conduct at the forefront of everyday decision making. Although laws and standards may change from country-to-country and culture-to-culture, all employees share the common goal and commitment to maintain the highest standards of ethics wherever we operate. Because COMSAT, Inc. requires the utmost ethical standards from all employees and agents, we have developed an anti-corruption policy that applies globally and to all employees and anyone acting on behalf of the company. Our commitment to ethics starts at the top with management and all employees are bound by our shared anti-corruption policy. We also endeavor to extend this spirit of excellence in ethical conduct to our customers, agents, vendors, suppliers, joint venture partners, independent contractors and anyone else that COMSAT, Inc. does business with. We understand that no policy can anticipate all possible ethical and legal situations, and thus sound judgment and discretion should always be used in assessing a situation which could violate COMSAT, Inc.’s ethics policies. Anti-Corruption Policy Prohibits offering or receiving anything of value, To or from anyone, Directly or indirectly, For the purpose of obtaining an improper business advantage, Or for any other improper purpose.