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Franklin Resources, Inc. Anti-Corruption Policy Overview

Purpose & Objective

This overview of Franklin Resources, Inc. Anti-Corruption Policy outlines the principles that FRI and its affiliates (collectively "FTI" or "we") follow to achieve zero-tolerance against bribery and corruption. The objective of our anti-corruption policy is to ensure that appropriate anti-corruption and bribery procedures are in place across the globe to avoid any violations of relevant laws and regulations, including, among others, the U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act 2010.

Scope

This policy applies to all officers, directors, shareholders, employees and appointed third party representatives of FTI (including but not limited to agents, intermediaries, consultants and introducers) in all locations. Violation of this policy will be severely sanctioned, including where appropriate disciplinary procedures, up to and including termination of employment and possible referral to the appropriate criminal or regulatory authorities.

FTI intends to review doing business with others who do not commit to the same standard of zero-tolerance of corruption, including joint ventures partners and distributors.

Policy Requirements

FTI has embedded within its business the following principles and controls to achieve zero tolerance against bribery and corruption:

Policy Requirements
No acceptance or offering of bribes and facilitating payments Strictly prohibited from giving or receiving bribes (i.e. personal benefit for any improper advantage) as well as facilitating payments (regardless of whether these are common practices in a particular country) which involve anything of value to government officials in order to expedite or facilitate routine, non-discretionary government actions
Charitable and political donations Prohibited from payment of donations that are linked to obtaining any improper advantage, including facilitating payments.
Gifts and Entertainment Prohibited from providing gift or entertainment to clients, prospects, government officials or their family members when such expenses are not incurred while conducting company business and/or do not satisfy this policy and our related policies.
Payment & Recordkeeping All relevant expenditures must be properly documented, approved and maintained for a minimum of 6 years.
Government officials Required to adhere to our additional recordkeeping requirements regarding all expenditures related to government officials. Written prior approval is required when a certain threshold is exceeded.
Due Diligence on Third-Party Representatives Required to conduct an appropriate due diligence review on background, reputation, and business capability before engaging or contracting with any third-party representatives and to include anti-corruption provisions in any such contract.
Periodic training Required to carry out appropriate training to employees regarding the Anti-Corruption Policy and their role to ensure compliance.

Monitoring and Reporting
We shall monitor compliance with our Anti-Corruption Policy. Further, all persons covered by this policy must promptly report any violation or suspected violation of this policy to the Deputy General Counsel - International, the Director of Compliance or the Compliance and Ethics Whistleblower Hotline.

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    For U.S. residents only.