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Global Anti-Corruption Policy

Plume Design, Inc. (“Plume” or the “Company”) is dedicated to fostering and maintaining the highest ethical standards. Bribery and corruption are prohibited by the laws of many countries in which Plume does business, including by the United States Foreign Corrupt Practices Act of 1977, as amended (the “FCPA”), United Kingdom Bribery Act of 2010, as amended (the “Bribery Act”), and other applicable anti-corruption or anti-bribery laws (collectively referred to as the “Anti-Corruption Laws”). It is the policy of the Company to fully comply with both the letter and spirit of the Anti-Corruption Laws.

The purpose of this Global Anti-Corruption Policy (this “Policy”) is to describe the practices and procedures that the Company’s officers, directors, and employees (“team members”), as well as its distributors, consultants, agents, contractors, business partners, and any other third-party representatives that act on the Company’s behalf (“Third-Party Representatives”), must follow to ensure that the Company’s practices meet or exceed all applicable legal and ethical standards. Team members and Third-Party Representatives are collectively “Covered Persons.” This Policy is intended to inform Covered Persons of the Policy and to help Covered Persons comply with Anti-Corruption Laws.

This Policy is implemented and overseen by the Company’s CFO (“CFO”) and may be amended at any time at the Company’s discretion. The Company requires annual certifications from all team members certifying that they have read and understand this Policy. The Company does not expect Covered Persons to become experts in compliance with the Anti-Corruption Laws. However, the Company expects and requires Covered Persons to be familiar with the requirements of such laws and to seek guidance regarding any conduct that may present a risk of violating the Anti-Corruption Laws or this Policy. Please consult with the CFO or his/her designee should you have any questions or concerns.

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