X. ANTI-BOYCOTT LAW

The Export Administration Act of 1979 prohibits any activity in support or furtherance of any restrictive trade practices or boycott imposed by foreign countries against other countries friendly to the United States or against any United States person. The law prohibits the Company from (1) refusing to do business with a person or country for boycott reasons, (2) agreeing to comply with laws of a boycotting country or agreeing that the laws of that country will apply to a particular transaction and (3) taking discriminatory actions or furnishing information in furtherance of or in support of a foreign boycott.

In particular, certain member countries of the League of Arab States enforce a boycott of Israel. The United States anti-boycott law, in general, prohibits the Company from furnishing any information to any of the Arab countries, or companies in those countries, relating to the Company's dealings or lack of any dealings with Israel. Employees must always be alert to "boycott requests" for any such information as they are commonplace in business documents such as letters of credit and shipping documents.

A "boycott request" is broadly defined to include a request to do anything, including the supplying of information, which could be considered to further or support any unsanctioned foreign boycott such as the Arab boycott of Israel. Boycott requests may originate from a wide variety of sources and may be oral or written. Typical examples of boycott requests include: (1) questionnaires or other inquiries from Arab boycott offices or other governmental authorities seeking information about relationships with Israel, "blacklisted" countries or any country that is subject to an unsanctioned boycott; (2) requests from customers or foreign import authorities seeking confirmation that goods or services are not of Israeli origin or that the freight insurer, vessel or others associated with the transaction are not "blacklisted" or that goods or services are not from any country that is the subject of an unsanctioned foreign boycott; (3) requests from governmental agencies or contractors as to the religion or national origin of persons in the management of a firm; and (4) clauses in contracts or shipping documents that require the firm doing business with an Arab country (or any other country supporting an unsanctioned foreign boycott) or customer to comply with the local boycott laws and regulations or with local laws generally, which include boycott provisions.

Since the mere receipt of a boycott request is a reportable event by law, all employees should immediately seek advice from the Law Department if any such request is received that solicits the Company's involvement in a restrictive trade practice. No action of any kind should be taken in response to any such request until guidance is received from the Law Department.