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UNDERSTANDING BRIBERY ISSUES TABLE OF CONTENTS Glossary of terms ...

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UNDERSTANDING BRIBERY ISSUES

TABLE OF CONTENTS Glossary of terms ....................................................................................................................... 1 Introduction ................................................................................................................................ 3 What is corruption? .................................................................................................................................. 3 Why do we care? ....................................................................................................................................... 4 Legislative landscape................................................................................................................................. 4 Penalties for corruption ............................................................................................................................ 5 Additional considerations ......................................................................................................................... 6 What is bribery? ......................................................................................................................... 7 Kickbacks ................................................................................................................................................... 7 Common transactions ............................................................................................................................... 8 Government officials ................................................................................................................................. 8 Intermediaries ........................................................................................................................................... 9 Facilitation payments ............................................................................................................................. 10 How can you avoid Corruption? ................................................................................................11 Which red flags to look out for? .............................................................................................................. 11 What to do when confronted with corruption?....................................................................................... 12 Where to turn for help............................................................................................................................. 13 Reporting Violations ..................................................................................................................14 Confidential business conduct hotline .................................................................................................... 14 Confidential e-mail.................................................................................................................................. 14

GLOSSARY OF TERMS Bribery

Bribery is the exchange of something of value to secure an undue, unwarranted or improper business advantage. A bribe may take the form of a financial inducement, a gift in kind, or some other favour such as an offer of employment to a relative of the person being bribed.

CFPOA

The Corruption of Foreign Public Officials Act of 1999 (CFPOA) is Canada’s anti-corruption law, which imposes criminal penalties on Canadian and foreign national individuals and corporations for bribes paid to foreign government officials. It was enacted to ratify the OECD Anti-Bribery Convention in Canada.

Extortion

Extortion is the use of a threat to induce or force someone to engage in undesired activity or behaviour, typically involving the loss of money or some other benefit from the extorted party. In the context of corruption, an example of extortion would be a government official who demands monetary payment against a threat to use their power to damage the interests of a company or an individual.

Facilitation payments

Facilitation payments are small payments to officials with a view to speeding up routine governmental transactions to which the payor is already entitled.

FCPA

The Foreign Corrupt Practices Act of 1977 (FCPA) is the main anticorruption law of the United States. The FCPA prohibits individuals and corporations from paying or offering bribes (including kickbacks) to foreign officials. It imposes strict criminal sanctions for individuals and corporations who violate the act, as well as civil liabilities for improper record keeping.

Fraud

Fraud is a deceitful act committed to secure an unwarranted, unfair and/or unlawful benefit. Corruption is therefore a form of fraud, committed against the public or a private organization by the person who receives the bribe or kickback.

Government Official

Government official (or “foreign official”) means not only traditional representatives of governments at the federal, state and municipal levels (appointed or elected), but also a wide range of civil servants and employees of state-owned or state-controlled entities. Government or foreign officials include officers or employees of foreign governments, public international organizations, and any department, agency, or related government or public international entities. It also includes any person acting in an official capacity for or on their behalf.

-2Kickbacks

Kickbacks are a mechanism to commit bribery and arise when suppliers or service providers pay part of their fees to the individuals who give them the contract or some other business advantage.

Money laundering

Money laundering is the process by which the true origin and ownership of illicitly-obtained funds is concealed. Corruption is frequently accompanied by money laundering to hide the illicit nature of bribes or kickbacks received.

OECD Anti-Bribery Convention

The Organisation for Economic Co-operation and Development Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (OECD Anti-Bribery Convention) is an international treaty intended to reduce corruption in international transactions. Signatories to the convention, including 34 OECD members and 6 non-members as of March 2013, are required to adopt domestic legislation to combat corruption involving individuals and corporations based in their countries. While the convention does not carry the force of law itself, it has served as the impetus for most domestic anti-corruption legislation around the globe, including the CFPOA, UK Bribery Act and many others. Similarly, the OECD serves as a watchdog for assessing the effectiveness of domestic anti-corruption legislation and promotes such legislation in countries where it is yet to be enacted.

PEPs

Politically-exposed persons (or PEPs) are past or current officeholders, or individuals who are or were formerly entrusted with high-level public functions in a foreign country, as well as their immediate family members and close associates. Examples of these positions of trust and power include senior politicians, heads of state or of government, senior judicial or military officials, and important officials of political parties as well as senior executives of stateowned enterprises.

State-owned enterprises

State-owned enterprises are legal entities which are fully or partially owned or controlled by the government. Employees and representatives of state-owned entities are considered government or foreign officials under most anti-corruption legislation.

UK Bribery Act

The Bribery Act of 2010 of the United Kingdom is an anti-corruption law that prohibits the paying and receiving of bribes to foreign officials (including kickbacks) by individual British nationals and corporations that have a branch or subsidiary in any part of the United Kingdom. It also imposes serious criminal sanctions on both individuals and corporations for violating the act. It was enacted to ratify the OECD Anti-Bribery Convention in the United Kingdom.

-3INTRODUCTION WSP Global Inc. and their subsidiaries (collectively, the “Company”) take corruption issues very seriously. Our management is committed to maintaining the highest standards of professional and ethical conduct, a commitment reflected in our culture and our policies. One of those standards is our zero-tolerance policy on corruption, in all forms, committed by our employees or third parties acting on our behalf. We join the ranks of the world’s leading businesses, multilateral organizations and local governments across the globe in the fight against corruption. We make this commitment on ethical grounds and because the Company and its employees could be held legally accountable for violating anti-corruption laws, with extremely severe penalties. As the Company continues to increase its international reach, our employees will likely face a wide range of transactions and projects in complex jurisdictions. This includes competitive bids for government and commercial contracts in countries where bribes, kickbacks and facilitation payments may be viewed as a part of doing business. The Company, however, takes a strong stand against such behaviour. We do not tolerate corruption. This document helps Company employees to understand the wider international context surrounding corruption challenges and the legal and ethical reasons that explain our zerotolerance approach. It will also help employees and our business partners to recognize, avoid and deal with situations where bribery and corruption are likely to surface. This document should be read in conjunction with our Code of Conduct, as well as our policies on Working with Third Parties and Gifts, Entertainment and Hospitality. What is corruption? There is no universal definition of corruption. Corruption watchdog Transparency International defines it as “the abuse of entrusted power for private gain.” As such, corruption characterizes a wide range of pernicious behaviour; it can involve everything from petty payments to facilitate routine transactions to multimillion dollar payments to fraudulently secure large public concessions. It may involve any combination of bribery, kickbacks, extortion, fraud, deception, collusion and money-laundering, among other pernicious behaviours. No country is immune to corruption. Corrupt officials and illegal behaviour can be found throughout the world, including in most developed countries. But some jurisdictions present particularly challenging environments. Weak institutions and limited rule of law make some countries, including environments in which we operate, more likely to suffer from corruption. Likewise, increased interaction and exposure to government officials during competitive public bidding processes mean certain industries, such as oil and gas, mining, engineering and infrastructure, are also more prone to the influence of bribery and kickbacks. Since we operate in these high-risk segments, the Company and our employees must be especially astute.

-4While the Company does not tolerate any form of corruption, this document focuses on the forms of corruption that are expressly prohibited under international anti-corruption legislation: bribery, kickbacks and facilitation payments. As mentioned above, corruption also implicates a wide range of other dishonest behaviours as well as matters relating to our employees’ political and charitable contributions and involvement. For more information, consult the Company’s Code of Conduct, which provides further guidance on these and other related matters. Why do we care? Corruption in all forms is simply bad business. It potentially jeopardizes contracts by making them legally unenforceable. It places honest and fair businesses at a significant competitive disadvantage. It damages employee morale by undermining employee confidence in management and colleagues. And corruption frequently begets further corruption: paying bribes subjects businesses to corrupt officials who may continue to make ever-increasing demands. Corruption also harms the countries where the Company does business. It weakens public accountability and democratic values, undermining the rule of law. It channels public resources away from education, health and infrastructure. And it frequently results in sub-par, defective or dangerous work product, which can even cause injury or death in some cases. But, in addition to its harmful effects on business and society at large, there is another important reason you should care about corruption: it is entirely illegal. Legislative landscape The Company is subject to the Canadian Corruption of Foreign Public Officials Act (CFPOA), the United States’ Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act, among other anti-corruption laws. This means that the Company must adhere to the strictest anti-corruption laws in the world. They apply to all our employees and subsidiaries anywhere in the world, regardless of nationality or location, as well as third parties acting on the Company’s behalf. In general, these laws prohibit bribery, kickbacks and facilitation payments (in the case of the UK Bribery Act). International organizations such as the Organisation for Economic CoOperation and Development (the OECD) have also promulgated strict policy proscriptions against bribery and corruption in international transactions amongst its members and the international community. In addition to the CFPOA, FCPA and the UK Bribery Act, the Company is also subject to wide variety of local anti-corruption laws in the jurisdictions where we operate, many of which were adopted based on the OECD’s Anti-Bribery Convention. The international tide has turned strongly against corruption, and the Company has chosen to adopt the best and highest international standards. As discussed below, penalties for infringement of these laws include fines and prison sentences for individuals, and heavy fines — often running to hundreds of millions of dollars — for companies.

-5To ensure compliance with letter and the spirit of the applicable legislation and international environment, the Company has committed itself to a zero-tolerance policy toward any form of corruption. Bribery, kickbacks and facilitation payments, in particular, will not be tolerated by our management. As an employee of the Company, you must avoid any behaviour that is expressly prohibited by anti-corruption legislation in all circumstances. You must also use your judgement to avoid behaviours that even risk the appearance of corruption or malfeasance. It is therefore critical that you fully understand which activities are considered corrupt, especially when engaging with government officials. If you have any questions, concerns or require additional information about anti-corruption legislation, consult your senior manager or the Risk and Ethics team. Penalties for corruption Legal and regulatory penalties for corruption can be severe. Sanctions under the CFPOA, FCPA, and UK Bribery Act for individuals and businesses who engage in bribery and kickbacks beyond their jurisdictional borders (Canada, US and UK, respectively) include: •

Criminal liability – individual employees convicted of bribery (including kickbacks) may be imprisoned for several years and subject to heavy fines. The Company may also be held criminally liable. While jurisdictions vary in terms of the recommended sentencing for bribery, almost all include some form of prison sentence.



Civil liability – the Company and/or our affiliates may be required to pay economic damages and heavy fines. Similarly, bribery and kickbacks typically involve fraud and other forms of financial non-disclosure, subjecting us to economic fines and damages under securities laws and other financial regulation. In recent years, economic damages under anticorruption laws (especially the FCPA) have frequently reached into the hundreds of millions of US dollars. Penalties have even reached into the billions in a few high-profile cases.

Local laws in the jurisdictions in which we operate may also result in criminal and civil penalties, possibly with even stiffer penalties than the CFPOA, FCPA and UK Bribery Act. The Company and our employees may be liable even if we were unaware that the corrupt activity was occurring. Turning a blind eye is no defence to corruption. You have a duty to report behaviour or any activities where you suspect the Company, our employees or our business partners may be involved in corruption. Likewise, certain precautionary measures must be taken when engaging with third parties, which are provided in the Company’s policy Working with Third Parties.

-6Additional considerations In addition to criminal and civil liability under local and international laws, our direct or indirect involvement in corruption may also significantly disrupt our operations. Accusations and convictions for corruption may result in any one of the following: •

Debarment from operating in certain jurisdictions – development banks and multilateral organizations have adopted “blacklists” of businesses that have been involved in corruption. Similarly, businesses involved in corruption may be debarred from public sector projects in certain jurisdictions (businesses that have been convicted of corruption are mandatorily excluded from public sector contracts in the European Union, for example).



Exclusion from certain private tenders and projects – private businesses frequently refuse to engage in transactions with other businesses with prior accusations and convictions for corruption, which can be uncovered by simple due diligence investigations.



Termination of existing contracts – contracts obtained through corruption are often declared void and legally rescindable because of the fraud.



Irreparable reputational damage – recent years have seen perceptions of corruption by the international business community and local governments change from indifference to outrage and activism. Businesses with a reputation for corruption are increasingly isolated from important capital markets and international transactions. Similarly, individuals with a reputation for corruption and related offenses are unofficially barred from employment with leading global businesses.

The disruptive effects of a conviction or reputation for corruption cannot be overstated. The sections to follow will help you understand, recognize and avoid the forms of corruption expressly prohibited by international and local legislation (bribery, kickbacks and facilitation payments). However, if you have any questions about this document, the Company’s Code of Conduct, any of the supporting policy documents or any matters relating to corruption, consult your senior manager or the Risk and Ethics team.

-7WHAT IS BRIBERY? Bribery is perhaps the most well-known form of corruption. It is also the core target of most anti-corruption legislation. In general, bribery involves the exchange of something of value to secure an undue or unwarranted business advantage. Bribery can involve many different parties to the transaction, but it always involves at least two primary parties: the person who pays the bribe (the supply side) and the person who receives it (the demand side). Both raise serious ethical and legal issues and involve a breach of trust and duty by both parties. The bribe does not have to occur through cash or monetary payment. Bribes may take the form of any financial inducement, a gift in kind or some other favour such as an offer of employment to a relative of the person being bribed. Even a mere promise to offer something in the future in return for a business advantage constitutes bribery. As a general matter, you should never offer anything to a government official or business partner in the private sector that could cause them to breach a duty entrusted to them by a public or private organisation. This is especially true during a competitive bid, where even modest gifts can be misinterpreted as a bribe in certain contexts. Consult our policy on Gifts, Entertainment and Hospitality for more information. If there is ever a doubt about whether something could be considered a bribe, always seek consultation before engaging in the activity. Kickbacks Kickbacks are a scheme that arises when suppliers or service providers pay part of their fees to the individuals who give them the contract or some other business advantage. Kickbacks are a mechanism through which bribery can occur. Paying kickbacks to government officials to win a bid may be one of the most common bribery schemes. The classic kickback scheme typically involves a competitive public bid and an agent with ties to a government official overseeing the bidding process. The agent, who may also provide otherwise legitimate consulting or advocacy services, offers to represent one of the competitors for the project for a fixed or variable fee. However, the agent has either prearranged to pay the government official a portion of such fees on the side in return for awarding of the contract or negotiates this during the bidding process. The winning bidder may or may not know of this arrangement. As mechanism to engage in bribery, kickbacks are expressly prohibited by anti-corruption legislation. Similarly, kickbacks are also subject to anti-fraud and other related legislation, as payments and invoicing invariably involve financial misstatements and misrepresentations.

-8Common transactions Bribery and kickbacks may take place in an endless variety of transactions and scenarios. Common transactions include: •

Government tenders and concessions – government procurement of routine services to public concessions of large infrastructure or extractive projects are particularly prone to the influence of bribery. Bribes are typically paid to compromise the formal selection criteria and processes to benefit a particular bidder.



Private tenders – like government tenders, bribery and kickbacks in a private tender typically seek to unduly modify formal selection criteria and processes. Although not all anti-corruption legislation prohibits bribery during private tenders (the FCPA does not, for example), many laws applicable to the Company – including the UK Bribery Act and local laws around the world – prohibit this form of bribery.



Regulatory approvals and audits – interactions with licensing, tax, customs and other regulatory authorities are frequently subject to the influence of bribery and kickbacks. Bribes may be paid to regulators to receive approvals that otherwise would not have been granted or to disregard violations. For example, tax authorities in some countries will request bribes to disregard or lower corporate or individual tax liabilities.



Commercial agreements – even ordinary agreements for the purchase and sale of services or goods can be subject to bribery. A bribe or kickback may be offered to the purchaser to breach purchasing standards or criteria set by any organization. Again, many international and local laws applicable to the Company prohibit this form of bribery.

All of the above transactions involving bribery are strictly prohibited by the Company’s Code of Conduct. Government officials Though bribery and kickbacks of any form is never permissible under the Company’s policies, special care must be taken when engaging government officials. Most national and international legislation pay special attention to government officials. As a result, the Company’s employees must take particular care when involved in any business relationship or discussion with government officials. These include not only traditional representatives of governments at the federal, state and municipal levels (appointed or elected), but also a wide range of civil servants and employees of state-owned or state-controlled entities.

-9The FCPA, for example, defines “foreign official” as any officer or employee of a foreign government or any department, agency, or instrumentality thereof, or of a public international organization, or any person acting in an official capacity for or on behalf of any such government or department, agency, or instrumentality, or for or on behalf of any such public international organization. Enforcement proceedings in the US have also made it clear that employees of state-owned enterprises, such as Petrobras (the Brazilian state-owned energy company) and similar entities in other countries, fall within the definition of “foreign official.” For our purposes, you should always assume that officials working for state-owned enterprises or quasi-government agencies are in fact government officials, and therefore, special care must be exercised when engaging with them. In addition to current government or foreign officials, similar caution must be taken when engaging with their immediate family and close associates as well as former government officials (collectively known as “politically-exposed persons” or PEPs). Although there may be occasions where such engagements are entirely appropriate and justified, engaging with politically-exposed persons, as a general matter, may lead to circumstances that place the Company and our employees at risk. Pitfalls can be avoided by exercising good judgment and closely following our policies on Gifts, Entertainment and Hospitality and Working with Third Parties. Intermediaries Bribes and kickbacks can also occur directly or indirectly. Bribery occurs directly if one of our employees engages in the bribe. A bribery payment by one of our employees to a public official during a competitive tender is an example of direct bribery. Bribery and kickbacks occur indirectly if they occur through a third-party intermediary. As a practical matter, indirect transactions are by far the most common way bribery and kickbacks occur. Common third-party intermediaries used to commit bribery and kickbacks include: •

Agents



Representatives



Consultants



Joint ventures



Equity partners



Subsidiaries



Suppliers



Contractors

- 10 Although bribery often occurs with the full knowledge of all of the relevant parties, it can also occur where one or more of the participants remain entirely unaware, especially when it involves a third party. It is not enough to simply say you did not know. Precautionary measures must be taken whenever working with third parties, especially politically-exposed persons. For more information, consult our policy Working with Third Parties. Facilitation payments Facilitation payments are small payments to officials with a view to speeding up routine governmental transactions to which the payer is already entitled. Unlike bribery, facilitation payments do not result in the receipt of an undue or unwarranted benefit; rather, they simply speed up or facilitate the transaction, which is why they are sometimes known as ”speed money” or ”grease payments.” Examples include payments to speed up customs clearances and extra fees to officials to secure electricity connections. The Company prohibits facilitation payments. They are illegal in almost every country. They undermine good governance, and a willingness to make them often leads to demands for larger, more significant payments. Furthermore, laws like the UK Bribery Act do not distinguish between facilitation payments and other forms of bribery. We cannot afford to operate outside national and international laws. Demands for facilitation payments are relatively common in some of the jurisdictions in which we operate. If you think you may encounter a demand for facilitation payments, please consult the section entitled What to do when confronted with corruption? below for further guidance, and consult your senior manager or the Risk and Ethics team.

- 11 HOW CAN YOU AVOID CORRUPTION? Avoiding corruption is not meant to be an impossible task. In general, corruption can be avoided by appropriately following the Company’s Code of Conduct and our policies on Working with Third Parties and Gifts, Entertainment and Hospitality. Individual liability can be avoided by adopting your own zero-tolerance policy toward bribery, kickbacks and facilitation payments. Simply stated, you can do so by: 1. Never offering, paying, requesting or receiving bribes or kickbacks, even if you have been requested to do so by your senior manager or anyone else. 2. Never getting involved in any fraudulent or dishonest activity. 3. Never authorising any corrupt activities or behaviours, nor turning a blind eye to potentially corrupt behaviour by your subordinates or third parties acting on the Company’s behalf. 4. Never engaging in activities that could facilitate corruption, including drafting illegal agreements, drafting fraudulent claims, falsifying evidence, and giving false evidence in legal proceedings. 5. Never concealing any corrupt or potentially corrupt activity. Which red flags to look out for? In addition to the measures above, recognizing scenarios where corruption is likely to occur can help you avoid and prevent precarious situations in the first place. Good judgment and intuition must play a critical role. In general, suspicious or odd activity or behaviour during a competitive bid or commercial transaction should always be treated seriously, especially if it involves government officials and intermediaries. But you should also be aware of certain warning signs. These include: •

Officials or business partners with a general reputation for questionable behaviour



Competitive bids that require the use of designated intermediaries



Officials or business partners who request charitable or political donations during a competitive bid



Officials or business partners who request isolated meetings, especially after a request to include additional parties has been made



Odd requests relating to communications (private meetings, conversations, etc.) or payment mechanisms (off-shore payments, cash, etc.)

- 12 •

Suspicious last-minute changes to selection criteria for competitive bids, which tilt the bid overtly in our favour (excluding all other competitors, for example)



Officials or business partners who suggest they can provide favours or help on unrelated matters



Business partners who request unusually high commissions or fees

This list is by no means exhaustive, nor does the existence of one or more of these factors mean that you should refrain from the engaging in the transaction. Rather, if you recognize these or any other suspicious behaviour at the outset of any transaction, document your concern and consult your senior manager and/or the Risk and Ethics team. They can help determine if further investigation and precautionary measures are necessary. What to do when confronted with corruption? Our management will take every precaution to avoid situations that expose the Company and our employees to corruption and we will always support employees acting in good faith to abide by our policies. Our Code of Conduct and our policies on Gifts, Entertainment and Hospitality and Working with Third Parties offer important guidance to prevent circumstances which can give rise to corruption. The Risk and Ethics team is also readily available to offer guidance and advice whenever necessary. However, despite every precaution we can take, you may still confront challenging situations. If you are ever requested to pay a bribe or engage in a kickback scheme, consider taking the following actions: •

Politely refuse. Always treat officials with courtesy and never lose your temper. If you treat them well, they are more likely to reciprocate.



If the person requesting a bribe continues, inform them of the Company’s zero-tolerance policy and the international and local laws on anti-corruption to which we are subject



Request that any bribery demands be made in writing



Make a detailed record of the event and include witnesses if possible



Immediately report the incident to the Risk and Ethics team.

If you suspect a colleague or one of our business partners is involved in potentially corrupt behaviour, immediately make a record of the circumstances and report these to the Risk and Ethics team so we can formulate a response. The Company also recognizes that corruption-related demands in any form – whether bribes, kickbacks, facilitation payments or otherwise – are often backed by a form of extortion, in some cases including the threat of violence or personal harm. An extreme example would be a

- 13 demand for payment to secure an emergency admission into hospital, leaving no time to consult a local line manager. In such circumstances, the Company accepts that staff will need to use their best judgement in accordance with the company’s principles. Whatever happens, staff must report any incident where they feel forced to bribe or facilitation payment as soon as possible, and any payments made must be properly recorded. Remember that the Company’s management will support well-founded and rational decisions by employees facing such instances. Likewise, if you ever feel that reporting a bribe, kickback or facilitation payment by a colleague, superior or any other party requires anonymous reporting, you may report the questionable activity by phone or via the Internet. The information will be processed by an independent party (the director of Internal Audit) who will be required to advise the chairman of the Audit Committee. This situation is covered in the Complaint Procedure with respect to Irregularities in Accounting, Auditing and Controls, which is available on the Web and intranet sites. The reporting party need not identify him/herself and, as such, may remain anonymous. Where to turn for help If in doubt about any aspect of this policy and guidance, you should contact the Risk and Ethics team.

- 14 REPORTING VIOLATIONS Confidential business conduct hotline Please refer to the list below to find your local free number.Confidential e-mail [email protected]

- 15 INTERNATIONAL FREEPHONE NUMBERS

Country

Freephone active

Freephone number

Argentina Australia Austria

Yes Yes Yes

0800 6662603 1800 121 889 0800 281700

Bahrain Bangladesh

Yes Yes

Belgium Brazil Bulgaria Canada Chile China Netcom (North) China Telecom (South) Croatia Columbia Costa Rica Cuba

Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes

Cyprus Czech Republic Denmark Egypt Eire Estonia Finland France Germany Greece Hawaii Hong Kong Hungary Iceland India Indonesia Israel Italy Japan Korea (South) Latvia Lithuania Luxembourg Malaysia Malta Mexico Netherlands New Zealand

Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes

80004475 Bangladesh: dial 157001 then the caller will either get through to the operator or hear a recorded message which will then prompt them to dial 8779167615. 0800 71025 0800 891 8807 00800 110 44 74 1888 268 5816 123 002 004 12 00800 3838 3000 10800 441 0078 0 800 222 845 01800-944 4796 08000440101 For Cuba: dial 2935 then the caller will either get through to the operator or hear a recorded message which will then prompt them to dial 8779167615 800 95207 800 142 428 8088 4368 0800 000 00 23 1800 567 014 800 00 44 265 0800 116773 0800 900240 0800 182 3246 00800 441 31422 1866 293 2604 800 930770 06800 14863 800 82 79 000 800 440 1286 001 803 0441 1201 1809446487 800 783776 00531 78 0023 00308 442 0074 8000 26 70 8800 30 444 8002 4450 1800 807055 800 62404 01800 123 0193 0800 022 9026 0800 443 816

- 16 Norway Pakistan Peru Philippines Poland Portugal Puerto Rico Romania Russia Saudi Arabia Singapore Slovakia Slovenia South Africa Spain Sri Lanka Sweden Switzerland Taiwan Thailand Turkey United Kingdom UAE (United Emirates) USA Venezuela Vietnam

Arab

Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes

800 14870 00800 900 44181 080053611 1800 1442 0076 00800 441 2392 800 880 374 1866 293 1804 08008 94440 810 800 2058 2044 800 844 0172 800 4411 140 0800 004461 0800 80886 0800 990520 900 944401 011 244 5413 (dialling from Colombo omit 011) 0200 285415 0800 563823 0080 10 44202 001 800 442 078 00800 4463 2066 0800 374199 8000 44 138 73

Yes Yes Yes

1877 533 5310 0800 100 3199 120 11527

Where there is no Freephone number, please communicate in the following manner: Collect call/reverse charge number steps as follows: 1. Caller dials their country operator; 2. Asks for an international collect call or reverse charge to 0044 1249 661 808; 3. Operator will dial the number and speak to an Expolink Operator, who will accept the call and charges, 4. Country operator connects caller to Expolink, leaves the call and then the call takes place as normal.