APPENDIX II – TRANSACTIONS & REQUESTS (“RED FLAGS”) The below list of “Red Flags” is not intended to be exhaustive and is for illustrative purposes only. Individually, these warning signs do not prove the existence of illicit or improper activity, but they may suggest the need for further inquiry, consultation with legal counsel, or greater vigilance in managing, reviewing, and monitoring third parties. Please contact the Director, Human Resources immediately if you have any questions or concerns. 1. The Associated Person or third party has a reputation for accepting or demanding bribes and/or has requested to make or receive bribes. 2. The Associated Person or third party has been the subject of previous enforcement action for corruption related offences. 3. The Associated Person or third party has a reputation for having “special relationships” or wishes to hire companies or individuals closely associated with Government Officials or their relatives. 4. The Associated Person or third party is a Government Official or a Government Entity that employs current or former Government Officials. 5. The Associated Person or third-party requests that payment be made to a different country from where it is located or conducts business. 6. The Associated Person or third party requests an unexpected additional fee or commission to facilitate a service or to “overlook” potential legal violations. 7. The Associated Person or third party demands or offers lavish gifts or entertainment before commencing or continuing negotiations or the provision of services. 8. The Associated Person or third party’s description of its business structure is incomplete, unusual or overly complex or the contractual relationship is unnecessarily complex or there appears to be duplicative executed contracts. 9. The Associated Person or third party requires the use of an agent, intermediary, consultant, distributor or supplier not known to us. 10. The Associated Person or third party provides invoices which appear to be non- standard or customized or which lack detail (e.g., state only “for services rendered”). 11. The Associated Person or third party makes unusual requests (e.g., backdating or altering invoices, splitting of purchases to avoid procurement thresholds, asking for payments by unusual means, such as through bank accounts outside the country where services are being offered, to individuals or to third persons). - 16 -