Berger Group Holdings, Inc. and its subsidiaries and affiliates, including but not limited to The Louis Berger Group, Inc., The Louis Berger Group (Domestic), Inc., Louis Berger Holdings, Inc., Louis Berger Services, Inc. and Louis Berger International, Inc. (collectively, “Louis Berger”) 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 Louis Berger operations in the United States. Louis Berger 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) 100% directly or indirectly wholly owned subsidiaries located in the European Union and (b) business contacts of business intermediaries of directly or indirectly wholly owned subsidiaries or affiliates located in the EU (each, a "Business Intermediary") as part of Louis Berger’s anti-corruption vetting process ((a) and (b) are collectively referred to as, “Covered Individuals”).

With regard to Business Intermediaries, Louis Berger 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 Louis Berger personnel as necessary to complete the anti-compliance corruption review and vetting activities described in this Privacy Policy.

Louis Berger maintains reasonable security measures to safeguard Business Intermediary Data from loss, misuse, unauthorized access, disclosure, alteration or destruction. Louis Berger also maintains reasonable procedures to help ensure that such Business Intermediary Data is reliable for its intended use, accurate, complete and current. Louis Berger 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 Louis Berger'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, Louis Berger 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.

Louis Berger provides its employees in the European Union with information regarding the data transfers that are covered by Safe Harbor via separate policies and procedures.

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

Safe Harbor Privacy Contact:

For Employee Matters:

John Pryor
Vice President, Human Resources
412 Mount Kemble Avenue
PO Box 1946
Morristown, NJ 07962-1946
Tel 973-407-1566
Fax 973-267-6082

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



Effective Date: March 23, 2015