Doing Business Internationally

National is committed to the highest business conduct standards wherever it operates. National observes these standards worldwide, even at the risk of losing business. While no one can anticipate all the situations that may present challenges to doing business in the worldwide marketplace, the following guidelines always apply:

• Observe all laws and regulations, both U.S. and non-U.S., that apply to business abroad
• Do not cooperate with illegal boycotts, such as the boycott of Israel by Arab states
• Observe all licensing requirements and the requirements of applicable import and export laws
• Do not enter into an agreement with an agent or consultant or other third party that relates to National's business outside the United States unless it has been approved by the Company
• Observe all applicable privacy and data protection laws and regulations

The laws governing National's business in foreign countries are extensive and complex, and may be different from those in the United States. No new National services or products should be offered in any new country without prior approval, including approval by National's Export and Customs Administration Group, and then only in accordance with the applicable local country's regulations and requirements.

Import and Export Regulation/Trade Compliance

Because of the international nature of our business, National is subject to the import and export laws and regulations of the United States and certain foreign governments. These laws and regulations govern the international transfer of all products and services of National, as well as technology, information and ideas belonging to National.

Under U.S. law, no technology may be exported without the proper government export licenses and documentation. Exports of technology include not only technology shipped via freight, but also technology that is hand-carried (employees traveling overseas), sent via courier services or U.S. mail, electronically transmitted or accessed, and/or disclosed to foreign nationals in the United States or abroad. "Technology" is very broadly defined and includes without limitation hardware, software, technical documentation, product specifications, technical data, as well as the ideas behind them.

It is your responsibility to ensure that proper documentation accompanies each export or disclosure. Failure to export or re-export without the proper export license or documentation can jeopardize National's compliance with U.S. export laws, as well as those laws of foreign countries. Non-compliance can result in denial of export privileges, criminal penalties, seizure of products, and fines to National and its employees.

It is National's policy to comply fully with all applicable U.S. and foreign laws controlling the export and re export of products, technology (including software) and services. You must exercise the necessary diligence to ensure that National complies with all applicable U.S. and foreign government regulations regarding exports. Any questions concerning export compliance should be addressed to the Export and Customs Administration Group.

Antiboycott Compliance

The United States has enacted anti boycott regulations that make it unlawful for U.S. persons to participate in any activity that could have the effect of promoting or supporting a boycott or restrictive trade practice of another country against customers or suppliers located in a country friendly to the U.S. or against a U.S. person, firm or corporation. Boycott issues arise most frequently in connection with the Arab boycott of Israel. Prohibited actions include, but are not limited to, furnishing information about business relationships with boycotted countries, or information about race, religion, sex or national origin. Requests for such information often appear in requests for proposals, shipping documentation, and letters of credit, but can occur in any context. You need to be sensitive to requests for such information. Any request for such information or to participate in boycott activities should be immediately reported to National's Legal Department or the Office of Business Conduct and Ethics. Violation of the anti boycott regulations can lead to significant sanctions, including fines, prison terms, and denial of export privileges.

Privacy and Data Protection Compliance

Many countries (including Canada, Argentina, Japan, Hong Kong and Australia and the European Union's Member States) have strict rules with respect to collection , use, disclosure and transfer of personal information about individuals, such as employees and consumers. Personal information includes any information that identifies or can be used to identify an individual, such as name, home address, contact information, or employee personnel information. Certain countries restrict transmission of personal information beyond their borders, unless certain requirements have been met. All employees should use care with respect to collection, storage and transmission of any personal information to ensure compliance with applicable privacy and data protection laws and regulations. All employees in any location should raise any questions about appropriate treatment of personal information with the Office of Business Conduct and Ethics.