An Anti-Bribery and Anti-Corruption Policy is an internal document that ensures that a business is conducted ethically and honestly. This policy prohibits the use of bribery and corruption in all forms, whether direct or indirect, involving public officials or private persons. The objective of this policy is to set forth the requirements that support the company's compliance with applicable laws relating to bribery and corruption, ensure that employees act in complete accordance with the policy, and set out the responsibilities of all employees and anyone acting on behalf of the company in observing and upholding the company's position on bribery and corruption. This policy applies to all employees, officers, and directors of the company, including its subsidiaries, affiliates, and related corporations, whether permanent or temporary.

The policy outlines the principles of anti-bribery and anti-corruption, which include prohibitions against engaging in or permitting a bribery offence to occur with the expectation or hope of receiving a business advantage or rewarding a business advantage already given. The policy also prohibits the acceptance of payment, gifts, or hospitality from third parties with the expectation that a business advantage will be provided in return. Staff is not allowed to engage in any activity that may lead to a breach of this policy.

The policy provides guidelines for giving and accepting gifts and entertainment, which must be occasional, reasonable, and appropriate, a normal business courtesy, transparent, and not in violation of the policy. The policy outlines the responsibilities of the staff, including mandatory anti-bribery and corruption training, reporting known or suspected bribery or corruption, ensuring that the company's standard anti-bribery and corruption legal clauses are incorporated into any contracts entered with counterparties, engaging with third parties that have established ethical business practices, and accurately notifying and maintaining records of all documentation linked to the giving or receiving of gifts and hospitality.

The company has established an anti-corruption committee responsible for accepting and registering relevant corruption cases, investigating reported cases, conducting anti-corruption related training for staff on how to recognise and deal with bribery and corruption issues, and ensuring implementation and compliance of the policy. Any breach of this policy will result in disciplinary action, including dismissal and/or termination of employment. The company may amend this policy at its own discretion, and the legal department will be the sole authority to interpret the content of this policy. For more information or further guidance, staff should contact the legal department representative.

How to use this Document?

1. Read and understand the General Purpose section of the document, which highlights the Company's stance against bribery and corruption.

2. Take note of the Purpose section that outlines the objectives of the policy, including the requirements for compliance with applicable laws, ensuring employees act in accordance with the policy, and defining the responsibilities of employees in observing and upholding the company's position on bribery and corruption.

3. Check the Scope section to see if the policy applies to you. Note that it applies to all employees, officers, and directors of the company and its subsidiaries and affiliates.

4. Review the Anti-Bribery and Corruption Principles section that outlines the prohibited actions, including bribery offences and accepting payments, gifts, or hospitality from third parties with the expectation of a business advantage.

5. Read the Gifts and Entertainment section, which provides guidance on giving and accepting gifts and entertainment in a transparent and ethical manner.

6. Understand the responsibilities of the staff, which include completing mandatory training, reporting any known or suspected bribery or corruption, ensuring compliance with the policy's legal clauses, maintaining accurate records of documentation, and submitting expenses claims in accordance with the company's policy.

7. Take note of the Procedure section, which highlights the role of the Anti-corruption committee in monitoring and implementing the policy.

8. Understand the consequences of violating the policy, which may result in disciplinary action, including termination of employment.

9. If you have any questions or need further guidance, contact the legal department representative.

10. Check the Revision and Explanation of the Policy section to see if there have been any updates to the policy. Note that the legal department is the sole authority to interpret the content of this policy.