APPENDIX B CHART 1A. FCPA Criminal Enforcement Statistics ( ) Natural Persons. Prosecutions of Natural Persons

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1 Appendix B

2 APPENDIX B CHART A FCPA Criminal Enforcement Statistics (998-) Natural Persons Prosecutions of Natural Persons Total No. No. Charged Pending as of end Discontinued Guilty Pleas Trial Convictions Acquittals No. Sentenced Charged with: of calendar year 3 without Sanctions 4 Year FB AM ML FB AM ML FB AM ML FB AM ML FB AM ML FB AM ML FB AM ML Total In this column, each natural person was only counted once, so the numbers represent the actual number of natural persons charged with FCPA violations in each year. For the purposes of this chart, the Department counted a natural person in each applicable column according to the conduct with which the defendant was charged. For instance, if a defendant was charged with both foreign bribery (FB) and foreign bribery related accounting misconduct (AM), the person was counted in both the applicable FB and AM columns. 3 For the purposes of this column, cases were deemed to still be pending if any of the following was true: () the defendant was charged, but not yet convicted; () the defendant was convicted, but not yet sentenced; (3) the defendant was sentenced, but had filed an appeal, which was still open; or, (4) the defendant was a fugitive, as of the end of the calendar year. 4 Since 998, there has not been a case in which the Department discontinued the prosecution of a natural person for foreign bribery or a related offense while imposing sanctions. Therefore, this category was excluded from this table. 5 For, the numbers in this chart are current through September 3,.

3 Total No. Charged 6 No. Charged with: 7 Pending as of end of calendar year 8 APPENDIX B CHART B FCPA Criminal Enforcement Statistics (998-) Legal Persons Discontinued with Sanctions Prosecutions of Legal Persons Discontinued without Sanctions Guilty Pleas Trial Convictions Acquittals No. Sentenced Year FB AM ML FB AM ML FB AM ML FB AM ML FB AM ML FB AM ML FB AM ML FB AM ML Total In this column, each legal person was only counted once, so the numbers represent the actual number of legal persons charged with FCPA violations in each year. 7 For the purposes of this chart, the Department counted a legal person in each applicable column according to the conduct with which the defendant was charged. For instance, if a defendant was charged with both foreign bribery (FB) and foreign bribery related accounting misconduct (AM), the person was counted in both the applicable FB and AM columns. 8 For the purposes of this column, cases were deemed to still be pending if any of the following was true: () the defendant was charged, but not yet convicted; () the defendant was convicted, but not yet sentenced; or, (3) the defendant was sentenced, but had filed an appeal, which was still open, as of the end of the calendar year. 9 For, the numbers in this chart are current through September 3,.

4 Total No. of Enforcement Actions Due to Conduct Involving: APPENDIX B CHART A FCPA Administrative/Civil Enforcement Statistics (998-) Natural Persons Administrative/Civil Enforcement Actions Against Natural Persons Pending as of end of calendar year Discontinued with Sanctions Discontinued without Sanctions 3 Discontinued as a Result of Civil Settlements Decisions with Sanctions Decisions Finding No Liability Year FB AM ML FB AM ML FB AM ML FB AM ML FB AM ML FB AM ML FB AM ML Total This column lists the number of enforcement actions taken against a natural person in each year from 998 through. If a natural person was subject to both an administrative proceeding and a civil enforcement action, these are counted as separate enforcement actions for the purposes of this chart. Also, if an enforcement action targeted more than one natural person, the number of enforcement actions recorded in this chart reflects the number of natural persons subject to the enforcement action. For the purposes of this column, cases were deemed to still be pending if any of the following was true: () a final judgment or settlement had not been reached; or, () the matter had been stayed pending the resolution of an ongoing criminal enforcement action against the defendant in question. 3 This column includes cases in which the civil charges against the natural person were dismissed by the Court. 4 For, the numbers in this chart are current through September 3,.

5 Total No. of Enforcement Actions 5 Due to Conduct Involving: APPENDIX B CHART B FCPA Administrative/Civil Enforcement Statistics (998-) Legal Persons Administrative/Civil Enforcement Actions Against Legal Persons Pending as of end of calendar year 6 Discontinued with Sanctions 7 Discontinued without Sanctions Discontinued as a Result of Civil Settlements Decisions with Sanctions Decisions Finding No Liability Year FB AM ML FB AM ML FB AM ML FB AM ML FB AM ML FB AM ML FB AM ML Total This column lists the number of enforcement actions taken against a legal person in each year from 998 through. If a legal person was subject to both an administrative proceeding and a civil enforcement action, these are counted as separate enforcement actions for the purposes of this chart. Also, if an enforcement action targeted more than one legal person, the number of enforcement actions recorded in this chart reflects the number of legal persons subject to the enforcement action. 6 For the purposes of this column, cases were deemed to still be pending if any of the following was true: () a final judgment or settlement had not been reached; or, () the matter had been stayed pending the resolution of an ongoing criminal enforcement action against the defendant in question. 7 This column includes one case in which the Department of Justice filed a civil forfeiture action against a certain monetary amount, plus interest, being held in a foreign bank account belonging to a foreign government, alleging that the money was the proceeds of criminal conduct including violations of the FCPA, as well as wire fraud and money laundering. The Department reached an agreement with the foreign government whereby, if the money is not claimed, it will be used to fund social and civil society programs in that country. 8 For, the numbers in this chart are current through September 3,.

6 APPENDIX B - CHART 3 SENTENCES OF NATURAL PERSONS CONVICTED AT TRIAL OF FCPA VIOLATIONS DEFENDANT CASE NUMBER AMOUNT OF BRIBES SENTENCE (excluding monetary penalties) Gerald Green (Owner/Film Executive) United States v. Green, et al., 8-CR-59 (C.D. Cal. 8) ~.8M 6 months imprisonment; 6 months home confinement Patricia Green (Owner/Film Executive) United States v. Green, et al., 8-CR-59 (C.D. Cal. 8) ~.8M 6 months imprisonment; 6 months home confinement William Jefferson (Congressperson) Frederick Bourke, Jr. (Investor) David Kay (Vice President) Douglas Murphy (President) Robert R. King (Employee) United States v. Jefferson, 7-CR-9 (E.D. Va. 7) United States v. Kozeny, et al., 5-CR-58 (S.D.N.Y. 5) ~ 5K + Equities ~ Millions 3 years imprisonment year and day s imprisonment United States v. Kay, et al., -CR-94 (S.D. Tex. ) ~ 58K 37 months imprisonment United States v. Kay, et al., -CR-94 (S.D. Tex. ) ~ 58K 63 months imprisonment United States v. King, et al., -CR-9 (W.D. Mo. ) ~.5M 3 months imprisonment 7 David H. Mead, (President, CEO, and Executive Vice President) United States v. Mead, et al., 98-Cr-4 (D. N.J. 998) ~ 5K 4 months imprisonment; 4 months home detention 8 Richard H. Liebo, (Vice President) United States v. Liebo, 89-CR-76 (D. Minn. 989) ~ 3K 8 months imprisonment (suspended); 6 days home detention United States Sentencing Guidelines Section B4., with a base offense level of 8, was the applicable U.S.S.G. Section at this time. After, Section C., with a base offense level of, became the applicable U.S.S.G. Section in accordance with international treaty obligations. In addition, corporate guilty pleas to FCPA violations resulted in over $. million in fines.

7 APPENDIX B CHART 4 SENTENCES OF NATURAL PERSONS WHO PLEADED GUILTY TO FCPA VIOLATIONS SINCE DEFENDANT CASE NUMBER SENTENCE REDUCTION FOR COOPERATION Nam Quoc Nguyen United States v. Nguyen, et al., (President/Owner) 8-CR-5 (E.D. Pa. 8) An Quoc Nguyen United States v. Nguyen, et al., (Employee) 8-CR-5 (E.D. Pa. 8) Kim Anh Nguyen United States v. Nguyen, et al., (Employee) 8-CR-5 (E.D. Pa. 8) Joseph T. Lukas United States v. Nguyen, et al., (Joint Venture Partner) 8-CR-5 (E.D. Pa. 8) Juan Diaz United States v. Diaz, (Intermediary) 9-CR-346 (S.D. Fla. 9) John W. Warwick United States v. Warwick, (President) 9-CR-449 (E.D. Va. 9) Charles Paul Edward Jumet United States v. Jumet, (Vice President; President) 9-CR-397 (E.D. Va. 9) Misao Hioki United States v. Hioki, (General Manager) 8-CR-795 (S.D. Tex. 8) Shu Quan-Sheng United States v. Quan-Sheng, (President, Secretary, and Treasurer) 8-CR-94 (E.D. Va. 8) Martin Eric Self United States v. Self, (CEO) 8-CR- (C.D. Cal. 8) Jason Edward Steph United States v. Steph, (General Manager) Jim Bob Brown (Managing Director) 7-CR-37 (S.D. Tex. 7) United States v. Brown, 6-CR-36 (S.D. Tex. 6) AMOUNT OF BRIBES SENTENCE (excluding monetary penalties) NO ~ 69K 6 months imprisonment NO ~ 35K 9 months imprisonment YES ~ 399K years probation YES ~ 8K years probation NO ~ M 57 months imprisonment NO ~ K 37 months imprisonment NO ~ K 87 months imprisonment YES ~ M 4 months imprisonment NO ~ 89K 5 months imprisonment NO ~ 7K years probation YES ~ 6M 5 months imprisonment YES ~ 6M year and day s imprisonment United States Sentencing Guidelines Section B4., with a base offense level of 8, was the applicable U.S.S.G. Section at this time. After November, Section C., with a base offense level of, became the applicable U.S.S.G. Section in accordance with international treaty obligations. Self pleaded guilty to the willful blindness provision of the FCPA.

8 APPENDIX B CHART 4 SENTENCES OF NATURAL PERSONS WHO PLEADED GUILTY TO FCPA VIOLATIONS SINCE DEFENDANT CASE NUMBER SENTENCE REDUCTION FOR COOPERATION Steven J. Ott (Executive Vice President) Yaw Osei Amoako 3 (Regional Director) Christian Sapsizian (Vice President) Roger Michael Young (Managing Director) Steven Lynwood Head 4 (Program Manager) Richard John Novak (Employee) Faheem Mousa Salam (Translator/Contractor) Richard G. Pitchford (Vice President; Country Manager) Gautam Sengupta (Task Manager) Ramendra Basu (Trust Funds Manager) United States v. Ott, 7-CR-68 (D. N.J. 7) United States v. Amoako, 6-CR-7 (D. N.J. 6) United States v. Sapsizian, et al., 6-CR-797 (S.D. Fla. 6) United States v. Young, 7-CR-69 (D. N.J. 7) United States v. Head, 6-CR-38 (S.D. Cal. 6) United States v. Randock, et al., 5-CR-8 (E.D. Wash. 5) United States v. Salam, 6-CR-57 (D.D.C. 6) United States v. Pitchford, -CR-365 (D.D.C. ) United States v. Sengupta, -CR-4 (D.D.C. ) United States v. Basu, -CR-475 (D.D.C. ) YES AMOUNT OF BRIBES ~ 67K SENTENCE (excluding monetary penalties) 6 months home confinement; 5 years probation YES ~ 67K 8 months imprisonment YES ~.4M 3 months imprisonment YES ~ 67K 3 months home confinement; 5 years probation YES ~ M 6 months imprisonment YES ~ 3K-7K 3 years probation YES ~ 6K 36 months imprisonment YES ~ 4K year and day s imprisonment YES ~ 5K 5 4 months home months imprisonment; confinement NO ~ 5K 5 5 months imprisonment 3 Judgment states defendant is hereby committed to the custody of the United States Bureau of Prisons to be imprisoned for a term of 8 months, including 6 months to be served in a halfway house. [Docket Entry 35] 4 Defendant pleaded guilty to violating the books and records provisions of the FCPA, not the anti-bribery provisions. 5 The defendants admitted to having taken steps in furtherance of the payment of a $5, bribe to a Kenyan government official, in violation of the FCPA. The defendants also admitted to having received $7, in kickbacks in exchange for using their positions with the World Bank to give favorable treatment to a consultant.

9 APPENDIX B CHART 4 SENTENCES OF NATURAL PERSONS WHO PLEADED GUILTY TO FCPA VIOLATIONS SINCE Richard K. Halford (CFO) DEFENDANT CASE NUMBER SENTENCE REDUCTION FOR COOPERATION Albert Reitz (Vice President and Secretary) Daniel Ray Rothrock, 4 (Vice President) Thomas K. Qualey (President) Darrold Richard Crites (President) Herbert Tannenbaum (President) Albert Jackson Jack Stanley 9 (Officer/Director) United States v. Halford, -CR- (W.D. Mo. ) United States v. Reitz, -CR- (W.D. Mo. ) United States v. Rothrock, -CR-343 (W.D. Tex. ) United States v. Qualey, 99-CR-8 (S.D. Ohio 999) United States v. Crites, 98-CR-73 (S.D. Ohio 998) United States v. Tannenbaum, 98-CR-784 (S.D.N.Y. 998) United States v. Stanley, 8-CR-597 (S.D. Tex. 8) AMOUNT OF BRIBES SENTENCE (excluding monetary penalties) YES ~.5M 5 years probation YES ~.5M 6 months home confinement; 5 years probation -- 6 ~ 3K year s probation NO ~7K 4 months home confinement; 3 years probation YES ~6K 7 confinement; 6 months home 3 years probation NO ~ K K 8 -- ~.8M year and day s imprisonment 84 months imprisonment; Rule (c)()(c) 6 There is no indication on the docket. 7 Crites was charged with paying a total of $57,39 in bribes to a Brazilian government official. In addition, Crites was charged with paying a total of $99, in bribes to an American government official as part of the same scheme. 8 Tannenbaum s plea agreement states that the value of the bribe was greater than $,, but less than $,. 9 Stanley has not been sentenced, but he was included in this chart since his plea was pursuant to Rule (c)()(c), with an agreed upon sentence of 84 months and restitution of $.8 million. The plea agreement also provides for the possibility of a sentence reduction below 84 months. 3

10 APPENDIX B CHART 5 SANCTIONS IMPOSED UPON LEGAL PERSONS FOR FCPA VIOLATIONS SINCE 998 CORPORATE ENTITY ABB Ltd (and two subsidiaries) Alliance One International (and two subsidiaries) DATE OF GUILTY DPA NPA PLEA CRIMINAL LENGTH OF CORPORATE COMPLIANCE MONITOR OTHER 9/9/ $9,, -- $,84,6 ; $6,5, (civil penalty) 8/6/ $9,45, 3 Years (anticipated) $,, Universal Corporation (and one subsidiary) 8/6/ $4,4, 3 Years $4,58,76.5 The Mercator Corporation 8/6/ Snamprogetti Netherlands 7/7/ $4,, -- $5,, Technip S.A. 6/8/ $4,, Years $98,, Daimler AG (and three subsidiaries) 4// $93,6, 3 Years $9,43,867 Innospec Inc. 3/8/ $4,, 3 Years $,, ; $,, (civil penalty - OFAC) Two subsidiaries of Alliance One International, Inc. are scheduled to be sentenced on October,. As part of their plea agreements, the two subsidiaries agreed to pay a total criminal monetary penalty of $9.45 million. The Mercator Corporation is currently scheduled to be sentenced on November 9,.

11 CORPORATE ENTITY APPENDIX B CHART 5 SANCTIONS IMPOSED UPON LEGAL PERSONS FOR FCPA VIOLATIONS SINCE 998 DATE OF GUILTY PLEA DPA NPA CRIMINAL LENGTH OF CORPORATE COMPLIANCE MONITOR OTHER Nexus Technologies Inc. 3/6/ BAE Systems plc 3// $4,, 3 Years -- UTStarcom Inc. /3/9 $,5, -- $,5, (civil penalty) AGCO Corp. (and one subsidiary) 9/3/9 $,6, -- $,4, $6,, Control Components, Inc. 7/3/9 $8,, 3 Years -- Helmerich & Payne, Inc. 7/3/9 $,, -- $375, Novo Nordisk A/S 5//9 $9,, -- $3,5,66 $6,5,79 Latin Node Inc. 4/7/9 $,, Kellogg Brown & Root LLC //9 $4,, 3 Years $77,, 3 As part of its plea agreement, Nexus Technologies Inc. admitted to having operated primarily through criminal means and agreed to dissolve itself and turn over all assets to the Court. Accordingly, on September 5,, Nexus was sentenced and ordered to permanently cease all operations and turn all net assets over to the Clerk of Court as a fine.

12 CORPORATE ENTITY Fiat S.p.A. (and three subsidiaries) APPENDIX B CHART 5 SANCTIONS IMPOSED UPON LEGAL PERSONS FOR FCPA VIOLATIONS SINCE 998 DATE OF GUILTY DPA NPA PLEA CRIMINAL LENGTH OF CORPORATE COMPLIANCE MONITOR OTHER //8 $7,, -- $3,6, $7,9,4 Siemens AG (and three subsidiaries) /5/8 4 $45,, 4 Years $35,, Aibel Group Limited //8 $4,, Years -- Faro Technologies, Inc. 6/5/8 $,, Years $,85, AGA Medical Corporation 6/3/8 $,, 3 Years -- Willbros Group Inc. (and one subsidiary) AB Volvo (and two subsidiaries) Flowserve Corporation (and one subsidiary) Westinghouse Air Brake Technologies Corporation 5/4/8 $,, 3 Years $,3, 3//8 $7,, -- $4,, $8,6, //8 $4,, -- $3,, $3,5, /4/8 $3, -- $87, $88, Lucent Technologies Inc. //7 $,, -- $,5, (civil penalty) 3

13 CORPORATE ENTITY APPENDIX B CHART 5 SANCTIONS IMPOSED UPON LEGAL PERSONS FOR FCPA VIOLATIONS SINCE 998 DATE OF GUILTY DPA NPA PLEA CRIMINAL Akzo Nobel N.V. //7 $8, (contingent upon Dutch disposition) Chevron Corporation /4/7 $,, (forfeiture); $5,, (to NYC District Attorney s Ingersoll-Rand Company Ltd. (and two subsidiaries) Baker Hughes Incorporated (and one subsidiary) LENGTH OF CORPORATE COMPLIANCE MONITOR OTHER -- $75, $,, -- $3,, (civil penalty-sec) $,, (civil penalty- OFAC) Office) /3/7 $,5, -- $,95, $,7, 4/6/7 $,, 3 Years $,, $4,, El Paso Corporation /7/7 $5,48,363 (forfeiture) -- $,5, (civil penalty) Vetco Gray Inc. /6/7 3 $6,, 3 Years -- (and three related subsidiaries) Schnitzer Steel Industries, Inc. (and one subsidiary) /6/6 $7,5, 3 Years $7,7, Statoil, ASA /3/6 $,5, 4 3 Years $,5, 4 Of the $.5 million criminal penalty imposed upon Statoil, $3 million was deemed to have been satisfied by a prior penalty paid to Norwegian authorities. 4

14 CORPORATE ENTITY APPENDIX B CHART 5 SANCTIONS IMPOSED UPON LEGAL PERSONS FOR FCPA VIOLATIONS SINCE 998 DATE OF GUILTY DPA NPA PLEA CRIMINAL LENGTH OF CORPORATE COMPLIANCE MONITOR OTHER DPC (Tianjin) Co. Ltd. 5//5 $,, 3 Years $,8, Micrus Corporation 3//5 $45, 3 Years -- Titan Corporation 3//5 $3,, 3 Years $5,479, ; $3,, (civil penalty) 5 Monsanto Company /6/5 $,, 3 Years $5, (civil penalty) InVision Technologies, Inc. /6/4 $8, 8 Months $5, $67,73.57 ABB Vetco Gray, Inc. (and one related subsidiary) 7/6/4 $,5, 9 Days 6 $5,95,45.64 Syncor Taiwan, Inc. (and its parent company) // $,, 3 Days 7 $5, (civil penalty) UNC/Lear Services Inc. 3// $75, -- $3, $768, (restitution) 5 Titan was ordered to pay a civil penalty of $3,,, but this obligation was deemed satisfied by the payment of a criminal fine in the same amount. 6 As part of the plea agreements and the judgment issued in the SEC s civil action, ABB Ltd. and its subsidiaries were required to retain an independent compliance consultant for a period 9 days. During this period, the consultant was to review and make recommendations regarding ABB s compliance programs. Except in certain circumstances, ABB was then required to implement the consultant s recommendations within 9 days of having received the consultant s report. 7 As part of the administrative cease-and-desist order issued by the SEC, Syncor International Corporation was required to retain an independent compliance consultant for a period 3 days. During this period, the consultant was to review and make recommendations regarding Syncor s compliance programs. Except in certain circumstances, Syncor was then required to implement the consultant s recommendations within 9 days of having received the consultant s report. 5

15 CORPORATE ENTITY APPENDIX B CHART 5 SANCTIONS IMPOSED UPON LEGAL PERSONS FOR FCPA VIOLATIONS SINCE 998 DATE OF GUILTY DPA NPA PLEA CRIMINAL LENGTH OF CORPORATE COMPLIANCE MONITOR OTHER International Materials /4/999 $, Solutions Corporation Control Systems Specialist, Inc. 3/8/999 $, Saybolt Inc. /6/999 $,5, (and one subsidiary) TOTALS 33 4 $,86,79, $,4,834,84 8 Saybolt Inc. was also fined $3,4, in a related criminal case involving the falsification of data from certain environmental tests of its products. 9 As part of its plea agreement, Saybolt Inc. was required to institute a compliance program related to its environmental testing program. 6

16 APPENDIX B CHART 6A Enforcement Actions with Regard to Alleged Foreign Bribery and Related Accounting Misconduct (Entries in columns 3-6 by number of investigations; entries in columns 7-8 by number of persons) Investigations Working Group member Alleged misconduct at issue Date of latest information supplied by WG member Date of entry into force of the Convention for WG member 3 ongoing Investigations 4 total to date Number of investigations in which assets seized or frozen pretrial Number of investigations to date having led to one or more proceedings Number of investigations to date not yet having led to any proceedings Number of discontinued investigations without sanctions 5 6.a 6.b 6.c 7 NP Persons sanctioned in connection with discontinued investigation (settlement, mediation, etc ) 8 LP United States Foreign bribery Foreign bribery related accounting misconduct 3 Dec 9 3 Dec 9 5 Feb Feb 999 More than 5 -- NP Natural Person The number of ongoing investigations reported here includes all open investigations into allegations LP Legal Person of foreign bribery and/or foreign bribery related accounting misconduct. The SEC, as a matter of policy, does not report on the number of ongoing, active investigations. Reported by all Working Group members Reported on a voluntary basis Notes by the United States: i) The Department of Justice (DOJ) is providing statistics for all criminal and civil enforcment actions undertaken by DOJ since: (a) the enactment of the OECD Anti-Bribery Convention (February 5, December 3, 9); and (b) the enactment of the Foreign Corrupt Practices Act (FCPA) (977-December 3, 9). The Securities and Exchange Commission (SEC) has reported numbers since the enactment of the Convention through December 3, 9. Therefore, the numbers contained within parentheses represent all DOJ enforcement actions since 977 combined with all SEC enforcement actions since 999. ii) For those DOJ and SEC enforcement actions in which a natural or legal person was charged with both foreign bribery and foreign bribery related accounting misconduct, one entry was made in each row under the applicable columns. iii) For both criminal and civil enforcement actions, DOJ and SEC counted as separate, in every applicable column, each individual legal person that was subject to enforcement actions and/or sanctions. This includes instances in which multiple subsidiaries of single corporation (or a parent corporation and one or more subsidiaries) were individually and/or jointly subject to criminal prosecution, administrative/civil proceedings, and/or criminal or civil sanctions. For example, in 7, Vetco Gray Controls, Inc., Vetco Gray Controls Limited, and Vetco Gray UK Limited were charged in a criminal information with violations of the anti-bribery provisions of the FCPA. All three companies pleaded guilty and were individually sentenced to a monetary penalty (in the amount of $6 million, $8 million, and $ million respectively) and a term of organizational probation. Accordingly, in this instance, three legal persons were counted in each of the following columns:, 8, 34, 37, and 5. Due to the size of the respective fines, two legal persons were counted in column 48d while only one legal person was counted in column 48e.

17 APPENDIX B CHART 6B Enforcement Actions with Regard to Alleged Foreign Bribery and Related Accounting Misconduct (Entries in columns 9-3 by number of persons) Proceedings Criminal Prosecutions (with formal charges) Administrative/Civil proceedings WG member Alleged misconduct at issue Date of latest information supplied by WG member Date of entry into force of the Convention for WG member Prosecutions (with formal charges) Discontinued prosecutions without sanctions/ condition Discontinued prosecutions with sanctions 3 Criminal convictions with sanctions 4 Acquittals Administrative/ civil enforcement seeking imposition of sanctions Discontinued administrative/ civil proceedings without sanctions Discontinued administrative/ civil proceedings with sanctions Administrative/ civil enforcement decisions with sanctions Administrative / civil decisions finding no liability Ongoing Total to date Ongoing Total to date NP LP NP LP NP LP NP LP NP LP NP LP NP LP NP LP NP LP NP LP NP LP NP LP United States Foreign bribery Foreign bribery related accounting misconduct 3 Dec 9 3 Dec 9 5 Feb Feb (67) () () () 83 () 5 () 39 (58) 3 (35) (8) () () () () () () () 38 (57) 3 (8) 7 (35) 8 () (6) (4) () () 3 (3) 3 (3) () () 36 (44) 38 (38) 8 (35) 5 (5) 4 5 (4) 4 5 (4) () () () () () () 9 (37) 3 (3) 8 (35) 5 (5) () () () () NP Natural Person 3 Those criminal prosecutions recorded as Discontinued with sanctions (columns 5-6) include LP Legal Person instances in which DOJ entered into either Non-Prosecution or Deferred Prosecution Agreements with the parties involved in the case. Reported by all Working Group members 4 Those criminal prosecutions recorded as Convictions with sanctions (columns 7-8) include Reported on a voluntary basis instances in which the defendants either pleaded guilty or were found guilty at trial. These columns also include those persons that have been convicted but that are still awaiting sentencing. Voluntarily dismissed with prejudice; that is, SEC asked the court to dismiss the action, while agreeing not to prosecute the defendants at a later date as a result of the same conduct. Notes by the United States: i) The Department of Justice (DOJ) is providing statistics for all criminal and civil enforcment actions undertaken by DOJ since: (a) the enactment of the OECD Anti-Bribery Convention (February 5, December 3, 9); and (b) the enactment of the Foreign Corrupt Practices Act (FCPA) (977-December 3, 9). The Securities and Exchange Commission (SEC) has reported numbers since the enactment of the Convention through December 3, 9. Therefore, the numbers contained within parentheses represent all DOJ enforcement actions since 977 combined with all SEC enforcement actions since 999. ii) For those DOJ and SEC enforcement actions in which a natural or legal person was charged with both foreign bribery and foreign bribery related accounting misconduct, one entry was made in each row under the applicable columns. iii) For both criminal and civil enforcement actions, DOJ and SEC counted as separate, in every applicable column, each individual legal person that was subject to enforcement actions and/or sanctions. This includes instances in which multiple subsidiaries of single corporation (or a parent corporation and one or more subsidiaries) were individually and/or jointly subject to criminal prosecution, administrative/civil proceedings, and/or criminal or civil sanctions. For example, in 7, Vetco Gray Controls, Inc., Vetco Gray Controls Limited, and Vetco Gray UK Limited were charged in a criminal information with violations of the anti-bribery provisions of the FCPA. All three companies pleaded guilty and were individually sentenced to a monetary penalty (in the amount of $6 million, $8 million, and $ million respectively) and a term of organizational probation. Accordingly, in this instance, three legal persons were counted in each of the following columns:, 8, 34, 37, and 5. Due to the size of the respective fines, two legal persons were counted in column 48d while only one legal person was counted in column 48e.

18 APPENDIX B CHART 6C Sanctions for Alleged Foreign Bribery and Related Accounting Misconduct (Except where noted, entries by number of persons sanctioned) WG member Alleged misconduct at issue Criminal Cases Exclusions or Total imposed Combined limitations on Monetary or agreed prison/- Prison access to Other sanctions 6 sanctions monetary only Prison sentences Monetary penalties imposed (USD) public only penalties 8 sanctions procurement or benefits < year - years -5 years >5 years Natural Persons Legal Persons NP LP NP NP LP NP a 47b 47c 47d 48a 48b 48c 48d 48e NP LP NP LP Total Suspend ed Total Suspend ed Total Suspend ed Total Suspend ed <K K- 5K 5K- 5K >5K K-5K 5K- 5K 5K- M M- M >M United States Foreign bribery Foreign bribery related accounting misconduct (39) (5) 38 (56) 3 (3) 3 (8) (3) () () 34 (5) 7 (9) 4 (7) () 4 (7) () () () 5 (7) () () () 6 (6) () () () (3) () () () 5 (8) () (7) () (6) () 5 (7) () (6) () (3) () 6 () 6 (7) 8 () 3 (3) 9 () 8 (9) (3) (4) (5) 7 (7) NP Natural Person 6 Criminal convictions are only recorded in columns 33 and 34 if the defendant has been sentenced. LP Legal Person 7 Debarment from public procurement processes is not handled by DOJ or SEC. For criminal cases, DOJ counted under Other penalties those natural and legal persons whose Reported by all Working Group members imposed or agreed sanctions included terms of community service, supervised release, and/or Reported on a voluntary basis probation. Notes by the United States: i) The Department of Justice (DOJ) is providing statistics for all criminal and civil enforcment actions undertaken by DOJ since: (a) the enactment of the OECD Anti-Bribery Convention (February 5, December 3, 9); and (b) the enactment of the Foreign Corrupt Practices Act (FCPA) (977-December 3, 9). The Securities and Exchange Commission (SEC) has reported numbers since the enactment of the Convention through December 3, 9. Therefore, the numbers contained within parentheses represent all DOJ enforcement actions since 977 combined with all SEC enforcement actions since 999. ii) For those DOJ and SEC enforcement actions in which a natural or legal person was charged with both foreign bribery and foreign bribery related accounting misconduct, one entry was made in each row under the applicable columns. iii) For both criminal and civil enforcement actions, DOJ and SEC counted as separate, in every applicable column, each individual legal person that was subject to enforcement actions and/or sanctions. This includes instances in which multiple subsidiaries of single corporation (or a parent corporation and one or more subsidiaries) were individually and/or jointly subject to criminal prosecution, administrative/civil proceedings, and/or criminal or civil sanctions. For example, in 7, Vetco Gray Controls, Inc., Vetco Gray Controls Limited, and Vetco Gray UK Limited were charged in a criminal information with violations of the anti-bribery provisions of the FCPA. All three companies pleaded guilty and were individually sentenced to a monetary penalty (in the amount of $6 million, $8 million, and $ million respectively) and a term of organizational probation. Accordingly, in this instance, three legal persons were counted in each of the following columns:, 8, 34, 37, and 5. Due to the size of the respective fines, two legal persons were counted in column 48d while only one legal person was counted in column 48e.

19 APPENDIX B CHART 6D Sanctions for Alleged Foreign Bribery and Related Accounting Misconduct (Except where noted, entries by number of persons sanctioned) WG member Alleged misconduct at issue Total imposed or agreed sanctions Monetary sanctions Administrative/Civil cases Monetary penalties imposed (USD) Exclusions or limitations on access to public procurement or benefits 9 Other penalties Suspended sentences Confiscation Confiscation or forfeiture of assets Natural Persons Legal Persons NP LP NP LP 57a 57b 57c 57d 58a 58b 58c 58d 58e NP LP NP LP NP LP NP LP <K K- 5K 5K- 5K >5K <5K 5K- 5K 5K- M M- M >M United States Foreign bribery Foreign bribery related accounting misconduct 9 (37) 3 (3) 8 (35) 5 (5) 6 (7) 9 (9) 3 (3) 44 (44) () () () () 4 (4) 6 (6) () () () () () 3 (3) 8 (8) 4 (4) 4 (4) 3 (3) () 4 (4) (37) 3 (3) 8 (35) 5 (5) () () () () 6 (6) 9 (9) () 44 (44) NP Natural Person 9 Debarment from public procurement processes is not handled by the DOJ or SEC. LP Legal Person For civil cases, DOJ and SEC counted under Other penalties those natural and legal persons who were subject to permanent injunctions or cease and desist orders against further violations of the Reported by all Working Group members FCPA. Reported on a voluntary basis Notes by the United States: i) The Department of Justice (DOJ) is providing statistics for all criminal and civil enforcment actions undertaken by DOJ since: (a) the enactment of the OECD Anti-Bribery Convention (February 5, December 3, 9); and (b) the enactment of the Foreign Corrupt Practices Act (FCPA) (977-December 3, 9). The Securities and Exchange Commission (SEC) has reported numbers since the enactment of the Convention through December 3, 9. Therefore, the numbers contained within parentheses represent all DOJ enforcement actions since 977 combined with all SEC enforcement actions since 999. ii) For those DOJ and SEC enforcement actions in which a natural or legal person was charged with both foreign bribery and foreign bribery related accounting misconduct, one entry was made in each row under the applicable columns. iii) For both criminal and civil enforcement actions, DOJ and SEC counted as separate, in every applicable column, each individual legal person that was subject to enforcement actions and/or sanctions. This includes instances in which multiple subsidiaries of single corporation (or a parent corporation and one or more subsidiaries) were individually and/or jointly subject to criminal prosecution, administrative/civil proceedings, and/or criminal or civil sanctions. For example, in 7, Vetco Gray Controls, Inc., Vetco Gray Controls Limited, and Vetco Gray UK Limited were charged in a criminal information with violations of the anti-bribery provisions of the FCPA. All three companies pleaded guilty and were individually sentenced to a monetary penalty (in the amount of $6 million, $8 million, and $ million respectively) and a term of organizational probation. Accordingly, in this instance, three legal persons were counted in each of the following columns:, 8, 34, 37, and 5. Due to the size of the respective fines, two legal persons were counted in column 48d while only one legal person was counted in column 48e.

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