Clear Channel Outdoor Holdings (CCO)

Policy on dealing with public officials

Companies that are part of the Clear Channel Outdoor group are often involved in bidding for contracts, franchises, etc. that are controlled by central and local governments.

It is unfortunately the case that there are rare occasions when officials or politicians accept some form of “bribe” (this being a gift of cash, valuable goods or valuable services) in return for giving preference to one bidder over another.

Clear Channel Outdoor has a strict and unambiguous policy that, whilst we are prepared to give substantial value to municipalities by way of products, services and, where appropriate, cash in respect of rent or revenue share, we will not under any circumstances give money, goods or services to the individual officials or politicians involved in the process of administering the tender or franchise in order to bias their judgement.

In simple terms, this means that if a public official says something like, “As part of the tender process are you prepared to fund a car for disabled transport?” we may well say “yes”. If the same official asks us to give him or her a car for their own use, we would obviously say “no”.

The policy is simple: whilst it is quite acceptable to provide public officials with normal levels of hospitality such as buying them lunch, a bottle of wine at Christmas, or inviting them to visit a conference, it is not acceptable to provide them with inducements to favour us over another bidder.

In practical terms, this means:

If you learn of any action that has been undertaken by an employee or agent of the company which might be construed as offering or making a “bribe” to a public official, you should send a written report on this to your Director.

18

Please confirm you understand and accept this policy by signing below.

I have read and understood this policy and I will ensure it is carried out in my Business Unit.

19