XXII. GOVERNMENT AND ATTORNEY INQUIRIES

The Company sometimes receives inquiries from government agencies and departments. These inquiries may take the form of letters, telephone calls or personal visits. It is the policy of the Company to comply with all applicable laws and to cooperate with any reasonable requests for information from the federal, state and local governments. However, in doing so, it is imperative that the legal rights of the Company and its employees be preserved and protected.

Whenever a request for information is received from any government branch, agency or department, the General Counsel of RAI or his designee should be notified promptly, before any response or acknowledgment is made. No employee should answer any question, submit to any interview, produce any Company information or hold any discussion or conversation with any government representative without prior consultation with the General Counsel of RAI or his designee.

It is recognized that there are some employees or functional groups within the Company that, due to the nature of their responsibilities, are in frequent and ongoing contact with certain federal, state or local regulatory agencies. In such instances, the General Counsel of RAI, or his designee, may provide general guidance and standing instructions, which define certain routine matters that do not require consultation with Company legal counsel prior to each response to, or contact with, the regulatory agency. Nevertheless, you must be alert to inquiries or requests for information that are either outside the scope of such defined routine matters or that come from an attorney on behalf of the regulatory agency. In these latter instances, you must consult with Company legal counsel prior to responding.

The foregoing considerations also apply to communications or inquiries from attorneys who represent parties other than the Company.