In conjunction with various applications to the State Administration of Foreign Exchange (“SAFE”) in Shanghai for approval of equity compensation awards to PRC nationals employed in China, Shanghai SAFE now has provided that applicants with previously granted equity awards in China must include, as part of its application package, a new letter of undertaking. In the letter of undertaking the applicant represents and agrees that it will: 1. Strictly comply with its obligations under Circular 7 and the applicable SAFE rules as currently in effect and as may be amended in the future, 2. Timely amend its application for any material changes in its equity compensation program as implemented in China, and 3. Ensure full repatriation of foreign exchange proceeds attributable to its equity compensation program implemented in China. For the sake of clarity, it is important to note that this letter of undertaking is in addition to the prior grant letter and prior grant data that must be provided to Shanghai SAFE as part of the application process. For additional information about this new letter of undertaking, please contact your GES attorney.