Policy Against Anti-Social Forces

1. Corporate Response – All employees of Pendo will work to avoid having any association or dealings with Anti-Social Forces. Pendo will work to ensure the safety of its employees when / if they are handling improper demands received from Anti-Social Forces.

2. Cooperation with Specialized Agencies – Pendo will cooperate with external specialized agencies such as the police, agencies working to eliminate organized crime, and attorneys in order to eliminate and / or appropriately respond to Anti-Social Forces activity.

3. Eliminating Relationships with Anti-Social Forces – In any case where a transaction turns out to be a transaction with Anti-Social Forces, Pendo will promptly take appropriate measures to cancel such a transaction.

4. Legal Response – Pendo will reject demands from Anti-Social Forces and will take appropriate responsive civil and / or criminal legal actions, as necessary.

5. Prohibition on Secret Transaction and Provision of Funds – Under no circumstances will Pendo knowingly engage in backroom dealings with, or provide funds to, Anti-Social Forces.

“Anti-Social Forces” as used herein means organized crime groups and their members and associates as well as those groups or individuals who use such measures as force, intimidation, violence and fraud to pursue economic benefit and / or disrupt civil order.