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 Services Subject to this Policy

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Payments for the following types of services are subject to the policy.  Note that this is not an all-inclusive list.

    ♦Consulting

    ♦Engineering

    ♦Repairs and/or maintenance

    ♦Construction

    ♦Fabrication

    ♦Installation

    ♦Commissioning of equipment

    ♦Training

    ♦Computer software services, including design, development, implementation, support, warranties, maintenance, training, website design, website hosting and certain software licenses

    ♦Communication services

    ♦Leasing of real or personal property

    ♦Use of intellectual property (patents, copyrights, etc.)

    ♦Media advertising

    ♦Accounting

    ♦Legal

    ♦Sweepstakes maintenance and/or hosting

    ♦Licensing of certain artwork (e.g. for use in rug design)

    ♦Transportation

Only payments for services performed in the U.S. are subject to this policy. However, the IRS considers many services performed in the U.S. if the recipients of those services are located in the U.S. As examples, the following are subject to this policy:

    ♦Website hosting performed in France where the website's visitors are located in the U.S.

    ♦Use of a Swedish patent in an industrial process located in the U.S.

    ♦Telephone and web-based conferencing services provided by a Canadian vendor where the users are located in the U.S.

Generally, this policy does not apply to the mere purchase of tangible property. However, if embedded services are included in the purchase, those services must be valued separately and are subject to this policy. An example of an embedded service might include the purchase of equipment for use in the U.S. where the vendor's engineers assist with installation at our U.S. plant.