United States of America

Corruption is a serious economic, social, political and moral blight, especially in many emerging countries. It is a problem that affects companies in particular, especially in international commerce, finance and technology transfer. The economic effects of corruption are well known: it leads to inefficient use of resources; it discourages productive investment, above all foreign investment; it hampers economic growth and erodes the standard of living; it unfairly redistributes wealth and income to the detriment of the poor; it inflates public spending, makes the tax system less efficient and swells the public deficit; it destabilizes national budgets, encourages capital flight and creates perverse incentives that stimulate income-seeking rather than productive activities, in a negative-sum game. The social and political effects of corruption are no less pernicious: it undermines the rule of law and democracy; it endangers good government, efficient public administration and sound corporate governance; it distorts the markets; it threatens fundamental human rights and subverts the institutions that guarantee stability, security and sustainable development. Also, corruption tends to spread, from one agency to the next and from one company to the next, reaching out towards organized crime, mafias and money laundering. From the ethical point of view, corruption is a violation of vital principles of social and economic life. It gives rise to negative learning that makes its diffusion particularly insidious and the task of preventing and combating it more difficult. Bribery of Non-U.S. Officials Strictly Prohibited. Compliance with the FCPA and the anticorruption laws of other nations is a priority for Global Crossing. Consistent with the FCPAs anti-bribery provisions, it is the policy of the Company that Global Crossing, its affiliates, Global Crossing Personnel and Third Parties are prohibited from corruptly paying, authorizing, offering to pay or giving anything of value to any Government Official (as defined below) outside of the United States or to any non-U.S. political party or party official or any candidate for political office (Other Covered Party) to obtain or retain business, direct business to any person or gain any other improper business advantage. This prohibition applies to any interaction with Government Officials or Other Covered Parties. Thus, it prohibits corrupt payments to obtain or retain contracts and any other illegal payment to a Government Official or Other Covered Party. Examples of improper actions under this Policy include: 1. Payment or offer of payment to influence a Government Officials or Other Covered Partys decision to award a contract or other business opportunity to Global Crossing. 2. Payment or offer of payment to influence a Government Officials or Other Covered Partys decision to issue any government authorization or documentation, such as any approval, permit or license;

3. Payment or offer of payment to influence a Government Officials or Other Covered Partys decision to relieve Global Crossing of otherwise required government obligations, such as paying taxes, passing inspections or obtaining required permits; 4. Payment or offer of payment to a Government Official or Other Covered Party to influence legislation or any judicial proceeding; 5. Any of the above made indirectly through a Third Party.