Speaking Up and Non-Retaliation

We believe that it is essential to create an environment in which individuals feel able to raise any matters of genuine concern, internally, without fear of disciplinary action being taken against them; that they will be taken seriously and that the matters will be investigated appropriately; and as far as practical, the discussed matter will be kept confidential. We prohibit retaliation, in any form, against anyone who, in good faith, reports violations or suspected violations of this Code, Company policy, or applicable law, or who assists in the investigation of a reported violation.

We encourage our Third Parties and their employees to promptly report any unethical conduct or concerns related to PALIG business as follows:

· Report directly to your PALIG Relationship Manager

· Email the Global Compliance & Ethics team at ethics@palig.com

· PALIG Ethics Hotline at palig.ethicspoint.com