VI. COMPETITIVE PRACTICES

The Company firmly believes that fair competition is fundamental to continuation of the free enterprise system. The Company complies with all applicable laws which prohibit restraints of trade, unfair trade practices or abuse of economic power. The Company will not enter into arrangements that unlawfully restrict its ability to compete with other businesses, or the ability of any other business organization to compete freely with the Company.

A Guide For Compliance With The Antitrust Laws, prepared and distributed by the Company to all employees, provides guidance for employees regarding legal requirements of, and compliance with, the various antitrust laws. This Guide is hereby incorporated by reference as a part of the RAI Code of Conduct. It is the responsibility of each employee to understand how the Guide applies to him or her and to abide by its terms and provisions. In connection with the annual certification of compliance with the Code, employees are also certifying that they have read the Guide and have complied with and followed the laws, policies and practices contained in the Guide.