Anti-Bribery & Compliance
Integrity · Transparency · Accountability

2. Prohibited Conduct

This policy explicitly prohibits the following conduct:

• Bribery: Directly or indirectly offering, promising, or giving anything of value to any government official, business partner, or third party to improperly influence their decisions or obtain an improper business advantage.
• Receiving Bribes: Soliciting, accepting, or agreeing to accept any bribe, kickback, commission, or other improper benefit.
• Facilitation Payments: Making any form of facilitation, expediting, or "grease" payment to speed up routine government actions (e.g., customs clearance, visa processing, etc.).
• Political Contributions: Making unauthorized political donations or party sponsorships on behalf of the Company.
• Charitable Donations: Using charitable donations as a cover for bribery, or making improper indirect payments through third parties.
• Commercial Fraud: Providing false information, forging documents, or engaging in any form of fraudulent conduct in commercial transactions.

3. Gifts and Entertainment

We recognise that appropriate gifts and entertainment can help build sound business relationships, but they must remain within legal, reasonable, and transparent boundaries.

• Permitted Gifts: Reasonably valued promotional items bearing the company logo, holiday gifts, etc., with an individual value not exceeding USD 50.
• Permitted Entertainment: Ordinary business meals, conference refreshments, etc., that are directly related to business purposes and of reasonable frequency.
• Prohibited Gifts and Entertainment: Cash, cash equivalents (e.g., gift cards), luxury items, recreational activities (e.g., golf, holidays, nightclubs), and any entertainment that could be perceived as improperly influencing decisions.
• Disclosure Requirements: All gifts and entertainment beyond routine levels must receive prior written approval from management and be properly recorded.

4. Third-Party Due Diligence

We partner only with those who share our standards of business ethics and compliance. Before establishing a business relationship with any agent, consultant, distributor, supplier, or joint‑venture partner, we require:

• Thorough background checks and compliance risk assessments of third parties
• Written commitments from third parties to adhere to our anti‑bribery and compliance policy
• Contractual compliance clauses, including clear consequences for violating anti‑bribery provisions
• Regular review and monitoring of third‑party compliance performance

We pay special attention to transactions involving government officials or state‑owned enterprises, as well as business activities in high‑risk countries or regions.

5. Financial Records and Accounting Transparency

We are committed to true and accurate recording of all business transactions and financial activities:

• All payments must be made through formal banking channels; cash or informal methods are prohibited
• All expense claims must be supported by genuine and complete supporting documents (invoices, receipts, etc.)
• Off‑book funds or secret accounts are prohibited
• Misstatement, concealment, or falsification of any transaction information in financial records is prohibited
• All records must be sufficiently detailed to accurately reflect the true nature of the transaction

6. Employee Responsibilities

Every employee has a duty to uphold the Company's compliance culture and business ethics. Employees shall:

• Be familiar with and understand this policy and its related procedures
• Always follow the highest standards of integrity in business activities
• Refuse to participate in any form of bribery or corruption
• Report suspicious conduct or potential violations promptly through appropriate channels
• Cooperate with compliance investigations and audits
• Participate in compliance training and awareness activities organised by the Company

7. Whistleblowing Mechanism

We encourage employees and business partners to promptly report any suspicious, unethical, or potentially policy‑violating conduct. We commit to:

• Providing multiple reporting channels: Reports may be submitted to the compliance department via email, telephone, or written correspondence.
• Protecting whistleblowers: Maintaining strict confidentiality of the reporter's identity and prohibiting any form of retaliation, discrimination, or adverse treatment.
• Allowing anonymous reporting: Anonymous reports are accepted, though we encourage providing sufficient information for effective investigation.
• Timely handling: All reports will be seriously investigated, and feedback will be given within a reasonable timeframe.

8. Consequences of Non‑Compliance

Individuals or entities that violate this policy will face serious consequences, including but not limited to:

• Employees: Disciplinary action, including warnings, suspension, demotion, dismissal, and, where applicable, referral to judicial authorities.
• Third Parties: Termination of contracts, cancellation of cooperation, claims for damages, and, where applicable, reporting to regulatory authorities.
• The Company: Liability for fines, reputational damage, and other legal consequences arising from non‑compliance.

We reserve the right to conduct internal investigations into any suspected violations and to take legal action where necessary.

9. Training and Awareness

We are committed to enhancing compliance awareness among all employees through continuous training and education:

• New employees receive anti‑bribery and compliance policy training upon onboarding
• Specialised compliance training is provided for employees in high‑risk roles
• Training content is regularly updated to reflect the latest laws, regulations, and best practices
• Compliance culture is continuously reinforced through internal communications, emails, and meetings
• Management leads by example, demonstrating a firm commitment to compliance

10. Policy Review and Updates

This policy will be regularly reviewed and updated to ensure it remains in line with the latest laws, regulations, industry standards, and best practices. Material revisions will be communicated internally and published on our website.

We encourage employees and business partners to periodically review this policy to stay informed about the latest compliance requirements.