Integrity and Anti-Corruption Compliance

We also maintain and comply with policies and procedures to identify and manage integrity and anti-corruption compliance risks. These includes policies with respect to anti-money laundering, FCPA, and combating the financing of terrorism that are in compliance with applicable national laws and regulations and consistent with international best practices.

With respect to our investments, transactions, and investors, Jaguar maintains a rigorous due diligence process: (A) to comply with all applicable U.S. and Foreign anti-corruption and anti-money laundering laws and regulations; (B) to use all commercially reasonable efforts to comply with best practices promulgated by international organizations such as the United Nations and the International Finance Corporation; and (C) to exclude persons and entities included on global “watch lists”, including the World Bank Listing of Ineligible Firms and Individuals (www.worldbank.org/debarr or any successor website or location) and the Office of Foreign Assets Control (OFAC) Specially Designated Nationals and Blocked Persons List (SDN).

Jaguar’s commitment to investing and doing business with the utmost integrity and responsibility is and will remain an essential element of our culture.