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ANTI-BRIBERY AND ANTI-CORRUPTION POLICY

1. INTRODUCTION

1.1 Mobile Land Systems FZ LLC (hereafter “Company”) is committed to achieving and
maintaining the highest ethical standards of corporate governance, transparency and
accountability as we uphold the principles of integrity and honesty in the conduct of our
business.

1.2 The Company has zero-tolerance to bribery and corruption. The giving and/or receiving of
bribes is contrary to our values and can play no part in the way we carry out our business. It
is in this spirit that this Anti-Bribery and Anti-Corruption Policy (hereafter “Policy”) is created.

1.3 This Policy is also a reiteration of our commitment and compliance with United Nations
Convention against Corruption, U.S. Foreign Corrupt Practices Act of 1977, and U.K. Bribery
Act of 2010 and other similar laws and regulations in all countries where we conduct our
business.

2. APPLICABILITY OF POLICY
2.1 This Policy is applicable to all employees, officers, and directors (hereafter “Person”) of
the Company.
2.2 It also applies to all of the Company’s business partners, including, but not limited to all
sales intermediaries, distributors, agents, advisers, consultants, subcontractors and relevant
third parties (hereafter “Business Partner”).
2.3 Person and Business Partner are jointly hereafter referred as Persons.
3. PROHIBITION

The following acts are hereby prohibited and any violation shall incur administrative, civil and
criminal liabilities in addition to indemnity for damages suffered by Company.

3.1 Bribery. Persons are guilty of bribery in the following cases:

3.1.1 Offering, promising or giving financial or other advantage in order to induce another to
perform improperly relevant function or activity or to reward another for the improper
performance.

3.1.2 Requesting, agreeing to receive or accepting financial or other advantage as a reward

3.1.3 In both above cases, it does not matter whether the advantage is offered, promised or
given directly or through a third party nor the other person knows or believes that the
performance of function or activity is improper.

3.2 Facilitation Payments. Are unofficial financial payments or other advantages either directly
or indirectly or through a third party nor the other person knows or believes that the
performance of a routine or necessary action to which the payer of the facilitation payment
has legal or other entitlement.

3.2.1 Persons are prohibited from making facilitation payments even if such payments are
local practice or custom.
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3.2.2 In certain limited situations where Facilitation Payments are lawful and unavoidable,
such must be approved by the Chairman of the Company. In addition, all Facilitation Payments
must be fairly and accurately recorded and accounted for.

3.3 Kickbacks. Kickbacks arise when suppliers or service providers pay part of their fees to
the individuals who give them the contract or some other business advantage.

3.3.1 Although kickbacks are typically made in exchange for business favor or advantage, the
Company does not allow kickbacks to be made or accepted.

3.4 Corrupting Public Officials. Corruption has the same attributes as bribery and can be
summarized as the misuse of entrusted power or office for personal gain.

3.4.1 Corrupting public official is a serious offense and can cause significant reputational
damage.

3.5 Gifts, Hospitality and Entertainment. It is acceptable if the gifts, hospitality and
entertainment are reasonable, made in good faith and in compliance with Company policy.

3.5.1 Persons may not offer to, or accept from, third parties, gifts, hospitality, rewards, benefits
or other incentives that could affect either party’s impartiality, influence a business decision or
lead to the improper performance of an official duty. Similarly, they may not offer or accept
cash donations.

3.5.2 Persons may offer and accept reasonable and proportionate gifts and entertainment,
such as dinner, theatre parties or sporting events. In determining what is reasonable and
proportionate, Persons should consider the value of the gift or benefit, as well as the frequency
with which the same or similar gift or benefit is offered.

3.6 Personal Conflict of Interest. It is a situation in which a person is involved in multiple

3.6.1 Persons must avoid situations or transactions in which their personal interests could
conflict or might be seen to be in conflict with the interests of the Company.

3.6.2 Personal interest can be direct or indirect, and refers not only to personal interests but
to those of family members and friends. If there is a potential for conflict, the interests of the
company must take priority.

3.6.3 Persons must disclose any personal conflict of interest or perceived conflict.

3.7 Doing Unlawful Business with the Government

3.7.1 Persons must be especially vigilant in dealing with all government officials. Activities that
may be permissible when working with private sector partners may be improper or illegal when
working with a government official.

3.7.2 Persons who have any questions regarding whether interactions with government
officials are appropriate should immediately contact the legal department of the Company.

3.8 Political Contributions. Person may not make contributions to any political party or public
international organisation, without the prior written approval of the Chairman of the Company.
The Company has policy of strict political neutrality.
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3.8.1 Persons are entitled to their own political views and activities, but they may not use
Company premises or equipment to promote those views or associate their views with those
of Company.

3.9 Penalty for Violation of Prohibition. If Person committed any of the prohibited acts herein,
disciplinary action may be taken against such individual which includes suspension or
termination.

4. BUSINESS PARTNER

4.1 The Company expects its Business Partner to approach issues of bribery and corruption
in a manner that is consistent with the principles set out in this policy.

4.2 The Business Partner acknowledges that it has received a copy of the Company’s Policy
and agrees to comply with the provisions of the Policy at all times during the term of this
Agreement.

4.3 The Business Partner shall indemnify the Company and each of its directors, officers and
employees from and against any liability, fine, loss or damage arising out of or in connection
with any breach of the Policy by the Business Partner.

4.4 In the event of any breach of the Policy by the Business Partner, Company may
immediately terminate this Agreement by written notice to the Business Partner. The indemnity
provided by the Business Partner in this clause shall survive any termination of this
Agreement.

4.3 Business Partners may be hired only after the completion of an appropriate level of due
diligence. Such due diligence may include: ownership, background checks, reviews of letters
of recommendation, reviews of credentials, reviews of financial statements, and contact with
local Chambers of Commerce, independent confirmation of the candidate’s history of
government employment and evaluation of the candidate’s other connections to government
officials, including family relations.

5. RECORD KEEPING

5.1 All of the books and records of the Company must fully and fairly reflect all expenditures.
Attempts to create false or misleading records are forbidden.

5.2 No payment on behalf of the Company may be approved without adequate supporting
documentation or made with the understanding that all or part of such payment is or has been
used for purposes other than those identified in supporting documents.

5.3 No undisclosed or unrecorded funds of the Company, such as off-the-books accounts,

5.4 No payments can be made, directly or indirectly, to undisclosed or unknown recipients, or

6. REPORTING

6.1 Any person concerned about any form of bribery, malpractice, improper action or wrong
doing by the Company, Person, or Business Partner are strongly encouraged to report the
matter to the Company’s legal department or management department.
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6.2 The Company gives assurance that these matters will be taken seriously and investigated
properly and no disciplinary action would be taken against the person who made such report.

6.3 Any employee, officer or director of Company who has direct knowledge of potential
violations of this Policy but fails to report such will be subject to disciplinary action.
7. WAIVER
7.1 No waiver or any deviation from this Policy is permitted.
7.2 And this Policy is intended to supplement all applicable laws, rules and other corporate
policies. It is not intended to supplant or replaced any national or international laws.
8. AMENDMENT OF THE POLICY
8.1 The Company will continuously monitor the effectiveness and review the implementation
of this Policy. Any improvements identified will be made as soon as possible and amendment
must be approved in writing by the Company’s Board of Directors.