C2E ANTI-CORRUPTION POLICY MANUAL

INTRODUCTION

Corruption prevents economic development, distorts competition, and undermines both the rule of law and the democratic
process. Local and international law applicable to C2E business activities around the world prohibit C2E and its employees
from engaging in corruption, such as the bribery of public and/or private sector officials. Extraterritorial application
of several anti-corruption regimes implies that it is not sufficient to observe local law when dealing abroad.

In accordance with well-established principles as described in C2E's Code of Conduct, C2E is committed to operate in
accordance with responsible, ethical, and sound business principles and comply with all applicable laws and regulations.
C2E specifically does not permit or tolerate engagement in any form of corruption. This manual explains and elaborates
the content and implications of C2E's policy in relation to anti- corruption.

No employee should assume that it is in C2E's interest to engage in any form of corrupt activity.

Absolute compliance with C2E's anti-corruption policy is required by all C2E employees at all times, and no C2E employee
may authorize another C2E employee to deviate from this policy.

Any failure to comply with applicable anti-corruption law will be considered a serious breach of the employee's obligations
towards C2E and will most likely result in termination of the employment or other applicable sanctions.

ABOUT THIS MANUAL

This manual provides an overview of C2E's anti-corruption policies and explains the basic legal and ethical requirements
that C2E employees shall follow to avoid corrupt practices throughout their business activities for C2E.

The policies discussed in this manual are mandatory for all C2E employees. It is also a requirement that C2E's
departments take reasonable steps under the circumstances to ensure that C2E's independent business partners,
including suppliers, do not engage in corruption or other illegal or unethical activities in relation to their business with C2E.

ANTI-CORRUPTION GUIDANCE AND REPORTING

On a day-to-day basis, you should seek guidance and direct anti-corruption inquiries from your immediate superior.
You may also contact the C2E Management if you have any questions about this manual or anti-corruption law.

Non-compliance with anti-corruption laws and C2E's anti-corruption policies is a serious breach of C2E's business principles
and may cause great damage to C2E. If you have reason to believe that employees or agents representing any C2E
company have engaged in, or intend to engage in, corrupt activities this should be duly reported.

WHAT IS CORRUPTION?

1.3.1 Legal Background

International conventions and agreements of the United Nations, the World Bank, the IMF, the WTO, the Organization of
American States, the OECD and the EU oblige the participating countries to implement comprehensive national legislation
against corruption. Corruption is restricted in most countries around the world. It is important to be aware that Norwegian
and other national anti- corruption legislation applies regardless of in which country the actions have been carried out and
regardless of whether corruption is lawful according to that country's national law. In practice, citizens and companies may
be prosecuted according to national anti-corruption legislation for acts committed anywhere in the world. Notably the United
States Government enforces extraterritorial jurisdiction to prosecute corrupt activities anywhere in the world according
to the U.S. Foreign Corrupt Practices Act (the FCPA).

1.3.2 Corruption Defined

While the specifics of anti-corruption law may be different in different parts of the world, most anti- corruption laws share a
common core definition of "corruption".
For the purpose of C2E's anti-corruption policy, corruption will include any attempt to directly or indirectly (through middlemen):

• Give or offer someone an improper advantage based on position, assignment, or duty (active corruption), or
• Demand, receive or accept an offer to receive an improper advantage based on position, assignment or duty (passive
  corruption).

Examples of corruption:

Bribing an official to obtain a contract is corruption. Corruption may also include activities such as
paying for illegitimate or unlawful travel or entertainment expenses for officials or their family members; agreeing to purchase
goods or services from officials or their friends or family members in return for favours; or donating to a charity linked
to an official in expectation of a benefit from that official.

1.3.3 Improper advantage:

Whether an advantage or benefit is improper will depend on concrete judgment, where
several factors may be relevant such as: the nature of the benefit, the position of the recipient, the relationship between the
parties and the specific context in which the benefit is being provided. Any benefit provided in return for the misuse of the
receiver's position, task or assignment will generally be considered an improper advantage. Please note that an advantage
can be improper even if no benefit is provided in return. An improper advantage will usually be a benefit in the form of
cash or objects with economic value but may also include benefits without economic value. Personal benefits provided in
relation to the recipient's position, task or assignment, such as services carried out for free or with a discount, invitations to
otherwise private organizations or clubs may easily be regarded as improper. Benefits in exchange for, or benefits that
constitute, a breach of statutory or contractual obligations, such as the receipt or delivery of proprietary information, will
by its nature easily be considered an improper advantage in regard to anti- corruption law. Benefits exchanged in relation
to discretionary acts and lack of transparency associated with granting of a benefit should be red flags for a potential
improper advantage.

1.3.4 Facilitation payments:

Facilitation payments are payments to secure the performance of routine governmental
action ordinarily performed by lower level officials, such as issuing non-discretionary permits, processing visas and other
papers, providing utility service, loading and unloading cargo, or protecting perishable products or commodities from
spoilage. Routine governmental action does not include decisions where the government official has legal discretion on
how he or she will act on the issue at hand. In accordance with applicable anti-corruption legislation, C2E has a general
policy against facilitation payments. This is further described in section 1.4.5 below.

1.3.5 Trading in influence:

Trading in influence is an offer of an improper advantage to, or acceptance to receive an offer
by, someone who has the ability to influence the performance of a position, assignment or duty. Trading in influence is a
particular offence similar to corruption and falls within C2E's anti-corruption policy.

1.3.6 Public and private sector payments prohibited:

The Norwegian Penal Code prohibits corrupt payments to any
person, including public officials and executives, employees, or agents of private sector companies. C2E's anti-corruption
policy prohibits corrupt activities of any type, whether those activities are related to a position, assignment, or duty
within public or private sector.

1.3.7 Liability for corrupt acts of affiliates or representatives:

Corruption may also include payments made by subsidiaries,
affiliates, agents or others acting on behalf of the parent Company or as part of the parent Company.

1.3.8 Accurate accounting:

Anti-corruption law requires that C2E have in place effective internal accounting controls
and maintain books and records that accurately reflect the companies' transactions. All entities within the Group must correctly
account for income and expenditures and must ensure that payments are not recorded falsely in Company books.
Misreporting or omitting a subsidiary's or affiliates bribes in the parent Company's consolidated accounts may in itself be
a breach of anti-corruption law (notably the FCPA) by the parent Company. (This does not mean that accurately reporting
bribes will somehow make them legal, but that the misreporting of such payments in an effort to conceal them is itself a
violation.)

21.3.9 Consequences of Non-Compliance

The potential consequences of non-compliance with applicable anti-corruption laws are substantial:

• Companies have been subjected to significant fines, penalties and government-ordered compliance costs as a result
  of corruption allegations.
• Companies may be prohibited from doing business in certain countries or industries, with certain governments or
  from participating in public tenders.
• Companies may be liable for damages claims by third parties disadvantaged by the corrupt activity, such as competitors
  who may have lost business.
• Corruption often results in negative publicity which can do tremendous damage to a Company's reputation and
  business relationships.
• The mere decision by relevant authorities to initiate investigation of a suspected anti- corruption infringement may
  cause serious harm to the involved party's reputation and business interests and trigger substantial costs.
• Individuals involved in corrupt activities may be subject to criminal sanctions, including fines, imprisonment, and in
  certain jurisdictions even corporal punishment.

RELATIONS WITH CUSTOMERS, SUPPLIERS AND PUBLIC OFFICIALS

1.4.1 General Principles

• C2E shall act in an open, ethical and lawful manner towards all potential or existing customers, suppliers, and public
  officials.
• C2E shall always perform its contractual obligations in accordance with the terms of the relevant contract unless
  deviations are approved by appropriate line management personnel and properly documented in Company records.
  Payments in cash or similar, or payments to unconfirmed recipients or account numbers shall not be accepted.
• All sales and marketing activities, coverage of third parties' expenses, payments and contract performance on behalf
  of C2E shall be open and transparent internally and vis-à-vis C2E's counterparties. Any invitation for individuals
  to participate in events or activities fully or partly paid by C2E shall be addressed to the appropriate management
  level within the relevant legal or public entity. Special caution must be exercised in relation to public officials and in
  situations where the recipient at the time is in a particular position to make a discretionary decision or act that could
  be beneficial to C2E. C2E employees must consult their supervisor if there is any doubt whether particular marketing
  or service activities conform to C2E's or relevant third party's anti-corruption policies.
• All expenses shall be approved under standard Company procedures and documented and recorded in accordance
  with appropriate accounting standards.
• Under no circumstances may any C2E employee receive or provide any kind of improper benefit from or to a
  supplier or business partner, including personal rebates, kickbacks, undocumented discounts, etc.
• C2E companies must take reasonable steps under the circumstances to ensure that C2E's business partners,
  including suppliers, do not engage in corrupt activities or other illegal or unethical activities. C2E employees
  who suspect that independent business partners are involved in corrupt activities must report and seek advice in
  the matter according to the procedures referred to in section 1.2 ; Anti- Corruption Guidance and Reporting.

1.4.2 Travel and Entertainment Expenses

Payment for reasonable and bona fide expenditures for seminars, travel, meals, lodging and entertainment for
potential or existing customers may be permissible if those expenditures are directly related to the promotion,
demonstration or explanation of C2E's products or services or the performance of a contract. The principles
in section 1.4.1 above apply correspondingly for C2E payment for the participants' expenses.
In addition, such payments:

• Must be directly related to bona fide marketing, business development or contract performance expenses.
• May not be provided, or appear to be provided, in expectation of or return for any benefit.
• Must be reasonable in amount, and appropriate under the circumstances.
• Must be verified through reasonably detailed documentation of actual expenses, including receipts and
  explanations of the payments' purposes and the legitimate business reasons for them.
• Must be in line with the receiver's Company policy and provided in an open and transparent manner.
• Payment of travel, meal, lodging or entertainment expenses for family members or friends of government or

1.4.3 Gifts

While exchanging gifts with customers, suppliers and business partners is a customary part of international business,
under no circumstances should C2E offer gifts of cash. Gifts other than cash may be permitted, however,they:

• Must be of minimal economic value, infrequent in nature and clearly appropriate under the circumstances.
• Must not be given in a context or a way where there are reasons to suspect that the recipient will keep
  such gift or benefit hidden from his or her superiors, e.g. gifts should be addressed to the recipient's working
  address at the relevant legal or public entity.
• Must not be provided in return for any benefit.

1.4.4 Political Contributions

Political contributions, such as contributions to the political campaign or fundraising efforts of public officials in
support of their ability to run for office may be viewed differently under the laws of the countries in which C2E
does business. Additionally, such contributions may have a potential impact on C2E's corporate image. Such
contributions must therefore be approved in advance by C2E. Requests for approval should be directed to C2E
Administration. If such contributions are approved, they must be provided in an open and transparent manner in
compliance with all applicable laws and accounting principles.

1.4.5 Facilitation Payments

"Facilitation payments ", as further explained in chapter 1.3.4 above, are payments to secure the performance of
routine governmental action and do not include discretionary decisions or acts. In accordance with applicable
anti-corruption legislation, C2E has a general policy against facilitation payments and does not justify facilitation
payments merely because it is customary or profitable in the circumstances.
In certain extortion-like situations facilitation payments may be necessary and justifiable in order to avoid a
significant harm to C2E's values or legitimate business interests. This will have to be assessed in the specific
circumstances at hand, but will generally not include any of the following:

• Payments of significant amounts.
• Payments made repeatedly to the same officials, or
• Payments of a type and nature which is treated as illegal by local law enforcement authorities.
• Facilitation payments should be distinguished from situations of true extortion, e.g. a direct threat of an unlawful
  tortious act vis-á-vis C2E's property in a situation that C2E could not foresee and where C2E is not able "to
  turn its back and walk away from the situation". Further, necessary payments to ensure personal health or safety
  are generally legitimate as an act of necessity.
• Any payments related to facilitation payments, or extortion shall, when possible, be properly authorized in
  advance through line management in consultation with C2E's Administration and shall always be reported
  to C2E's Administration and documented and recorded in accordance with normal Company accounting and
  control procedures.