GIBSON DUNN & CRUTCHER LLP

PRIVACY POLICY FOR PURPOSES OF THE U.S./EU SAFE HARBOR
AND U.S./SWISS SAFE HARBOR

GENERAL STATEMENT

Gibson Dunn & Crutcher LLP "GDC" is an international law firm, with clients located throughout the world, including in the European Union and Switzerland.  In representing such clients in transactional, litigation, or other matters, it is often necessary for the client to provide to GDC information that is subject to the jurisdiction of the European Union Directive on Data Protection or the Federal Data Protection and Information Commission of Switzerland (together, the "Directives").  This privacy policy is being implemented pursuant to the framework of the U.S/EU Safe Harbor and the U.S./Swiss Safe Harbor and adheres to the Safe Harbor privacy principles contained therein.  (Please note that the Notice, Choice and Access principles do not apply given that the data GDC will be using and/or processing is necessary for the establishment of a legal claim or defense or is related to acquisitions, mergers, joint ventures or other similar transactions where there is a need for confidentiality).
 
GDC'S HANDLING OF CONFIDENTIAL PERSONAL INFORMATION

GDC maintains the personal and confidential information it receives in secure on-line and off-line facilities.  Such information is not disclosed unless necessary or advisable to protect the rights, safety or property of GDC or others; to conform to legal or regulatory requirements; or as required to protect the legitimate interests of its clients relating to GDC's representation of such clients.  Such data is not disclosed to third parties other than to certain entities providing services to GDC, but only if such disclosure is permitted under applicable law and only if the third party operates in accordance with GDC's strict data standards, and for the purposes of GDC's representation of its clients. 

GDC maintains strict security and confidentiality policies that govern all information any attorney or other personnel of the Firm receives in the course of his or her employment or association with GDC.  All attorneys and personnel are made aware of these policies and the Firm has in place procedures to train all attorneys and personnel in the implementation of these policies.  Failure to adhere to the Firm's privacy policies results in appropriate discipline.  GDC has in place procedures for periodically conducting objective reviews of compliance with this Privacy Policy.

VERIFICATION MECHANISM AND ENFORCEMENT

Verification of GDC's privacy policy will be through self-assessment and verified by the Office of the Executive Director of the Firm in a signed statement that will be updated annually and referenced on the Firm's Internet.  GDC's Privacy Policy concerning personal information received from the EU and/or Switzerland is accurate, comprehensive, fully implemented and prominently displayed on the Firm's Internet. 

Mary P. Palmer, of the Firm's Office of General Counsel, is the designated contact for handling questions, complaints and other Safe Harbor issues.  Ms. Palmer can be reached at mpalmer@gibsondunn.com.  Any complaints concerning the Privacy Policy will be investigated, and if the Firm is unable to resolve the complaint to the satisfaction of all parties, the parties agree to utilize the dispute resolution mechanisms provided for by JAMS (see http://www.jamsadr.com/).