Imagina Non Prosecution Agreement

Under today`s non-prosecution agreement, Imagina Media took responsibility for its criminal conduct and its subsidiary Imagina US and also assumed responsibility for the failure to conduct an immediate internal investigation after learning of the charges against its agents in the first indictment. Imagina Media took responsibility, among other things, by inciting Imagina US to plead guilty to both counts in the information and by complying with all the terms of Imagina US`s argument with the government, and b) agreed to pay the sentence of 12,883,320 $US imposed on Imagina US as part of its sentence. In light of this liability, the corrective action taken so far by Imagina Media, including the termination of co-conspirator #1, Roger Huguet and Fabio Tordin, and the hiring of a new CEO, CFO and General Counsel, among others within Imagina US, and their commitment, including: a) to acknowledge and take responsibility for its conduct; b) continue their cooperation; (c) the establishment of enhanced internal controls and a rigorous corporate compliance programme, Including policies and procedures relating to Imagina US, Imagina Media and imagina Media, as well as other subsidiaries and associated companies, to detect and deter violations of all applicable federal, national and foreign corruption laws, the government entered into a non-prosecution agreement with Imagina Media and agreed to a 10% reduction in the end of existing criminal guidelines. If Imagina Media violates the non-prosecution agreement, legal proceedings are pending. In cases where monitoring is warranted, the Benczkowski Memorandum describes the initial selection – and, if necessary, replacement – procedures for the company`s monitor. First, the company can recommend three qualified candidates and identify one as a top choice. A “qualified candidate” is defined by his (1) general context, training, experience and reputation; (2) expertise in the (s) area (s) concerned (s); (3) objective and independent capacity; and (4) access to adequate resources to effectively assume its responsibilities. Within 20 days of a qualified agreement (for example. B NPA, DPA or Appeal Agreement), the company should submit a written proposal outlining the qualifications and qualifications of each candidate and certifying that the proposed candidates are not employed or bound by the company and that they are not employed or bound by the company for at least two years after the end of the supervision.