it will institute and thereafter comply with internal policies, procedures and controls, in line with applicable legislation and international best practices, for the purpose of preventing the Borrower to become, in connection with the implementation of the Project or otherwise, an instrument for money laundering or terrorism financing;

it will not make any Loan proceeds available to or for the benefit of, directly or indirectly, any Sanctioned Person;

it will not commit, and no person, with its consent or prior knowledge, will commit, in connection with the implementation of the Project or any Sub- project a Corrupt Practice, a Fraudulent Practice, a Coercive Practice, a Collusive Practice or an Obstructive Practice (hereinafter, together with money laundering, terrorism financing and making available any Loan proceeds to Sanctioned Persons referred to as the “Prohibited Practices”).

A “Corrupt Practice” means any act of offering, giving, receiving, or soliciting, directly or indirectly, anything of value to influence improperly the actions of another party.

A “Fraudulent Practice” means any act or omission, including a misrepresentation, that knowingly or recklessly misleads, or attempts to mislead, a party to obtain a financial or other benefit, or to avoid an obligation.

A “Coercive Practice” means any act of impairing or harming, or threatening to impair or harm, directly or indirectly, any party or the property of any party to influence improperly the actions of a party.

A “Collusive Practice” means any arrangement between two or more parties designed to achieve an improper purpose, including influencing improperly the actions of another party.

An “Obstructive Practice” means, in relation to an investigation into a Coercive, Collusive, Corrupt or Fraudulent Practice, (a) any act of deliberately destroying, falsifying, altering or concealing of evidence material to the investigation; (b) any act of threatening, harassing or intimidating any party to prevent it from disclosing its knowledge of matters relevant to the investigation or from pursuing the investigation; and/or (c) any act intending to materially impede the exercise of the contractual rights of audit or access to information.

to take timely such action as the CEB may reasonably request to investigate and/or terminate any alleged or actual Prohibited Practice;

to facilitate any investigation that the CEB may conduct concerning any alleged or actual Prohibited Practice; and

to inform the CEB of the measures taken to seek damages from the persons responsible for any loss resulting from any such Prohibited Practice.