SAFE HARBOR POLICY

The Louis Berger Group, Inc., The Louis Berger Group (Domestic), Inc., Berger Group Holdings, Inc., and Louis Berger Water Services (collectively, “Berger Group”) recognize that the European Union (“EU”) has an “omnibus” data protection regime established pursuant to the European Data Protection Directive (95/46/EC) (the “Directive”). Among other things, the Directive generally requires “adequate protection” for the transfer of certain individually identifiable data about individuals in the EU (“EU Personal Data”) to Berger Group operations in the United States. Berger Group accordingly adheres to the requirements of the EU Safe Harbor Privacy Principles published by the US Department of Commerce (“Safe Harbor”) with respect to certain EU Personal Data received in the United States about (a) employees of its affiliate HBF SAS and HBF SAS’s 100% directly or indirectly wholly owned subsidiaries located in France and the UK and (b) business contacts of business intermediaries of its affiliate HBF SAS and HBF SAS’s 100% directly or indirectly wholly owned subsidiaries located in the EU (each, a "Business Intermediary") as part of the Berger Group’s anti-corruption vetting process ((a) and (b) are collectively referred to as, “Covered Individuals”).

With regard to Business Intermediaries, Berger Group receives in the United States the types of personal data about such individuals necessary to perform its anti-corruption compliance review and vetting activities for third party intermediaries as required by United States and other applicable laws. Such information may include: name, title, company name and location, business contact information, information regarding criminal background or history and/or unlawful or objectionable behavior (where permitted by applicable law), project compensation information and related information necessary to perform the anti-corruption compliance review in the United States (such information is collectively referred to as "Business Intermediary Data"). Business Intermediary Data will be disclosed to limited internal Berger Group personnel as necessary to complete the anti-compliance corruption review and vetting activities described in this Privacy Policy.

Berger Group maintains reasonable security measures to safeguard Business Intermediary Data from loss, misuse, unauthorized access, disclosure, alteration or destruction. Berger Group also maintains reasonable procedures to help ensure that such Business Intermediary Data is reliable for its intended use, accurate, complete and current. Berger Group may engage third parties to provide anti-corruption review activities and related services as well as storage activities. Such third parties will be required to treat Business Intermediary Data solely in accordance with Berger Group’s instructions, and to implement appropriate technical and organizational measures to protect the security and confidentiality of such Business Intermediary Data. In addition, regardless of any other provisions in this Privacy Policy, Berger Group may disclose or otherwise process Business Intermediary Data in the context of any sale or transaction involving all or a portion of the business, or as may be required or permitted by law and/or the Safe Harbor.

Berger Group provides its employees in the France and the UK with information regarding the data transfers that are covered by Safe Harbor via separate policies and procedures.

Covered Individuals may contact the Berger Group’s Safe Harbor Privacy Contact identified below with questions and/or to review EU Personal Data that the Berger Group holds about them. Any such Covered Individuals who cannot resolve his/her issue directly with the Berger Group can contact the local data protection authority for further information and assistance.

Safe Harbor Privacy Contact:
For Employee Matters:

Terry Williams
Director, Human Resources
412 Mount Kemble Avenue
PO Box 1946
Morristown, NJ 07962-1946
Tel 973-407-1108
Fax 973-267-6082
twilliams@louisberger.com
For Business Intermediary Matters:

Michael Reap
Senior Vice President and General Counsel
412 Mount Kemble Avenue
PO Box 1946
Morristown, NJ 07962-1946
Tel 973-407-1087
Fax 973-267-6354
mreap@bergergroup.com


Effective Date: September 18, 2013