Anti-Bribery and Anti-Corruption

1. Purpose

1.1 Preventing corruption in an organization starts at the top. Senior management and the Board of Directors must pledge and be committed towards zero-tolerance of corruption and anti-bribery.

1.2 This policy formalizes our rules and principles for fair and honest business

2. Scope

2.1 This policy applies to all of the directors and employees of Anacle Systems Limited (“Anacle”) as well as the employees of Anacle’s subsidiaries.

3. Related Policies

3.1 This policy must be read in conjunction with COR-01 Business Ethics Policy.

4. Anti-Bribery and Anti-Corruption Policy

4.1 Anacle is committed to running our business operations on a foundation of Integrity, Transparency and Honesty. Anacle will devise and improve our processes continuously to prevent direct or indirect bribery, in order to safeguard and uphold our values.

4.2 Anacle adopts a zero-tolerance policy towards any forms of corruption and bribery in our business. Anacle and our employees have to observe the anti-bribery and anti-corruption legislations and regulations in the countries where we have business activities in and undertake ourselves to not engage in any corrupt or improper practices.

4.3 Anacle does not allow our employees to solicit or accept any benefits such as commissions, gifts in cash or kind, gifts that are more than nominal value, or any other service, favour or advantage of any description whatsoever, from any organisation, firm or individual with whom they deal with in the course of the employment.

4.4 Anacle does not allow our employees to promise or offer to give any benefits such as commissions, gifts in cash or kind, gifts that are more than nominal value, or any other service, favour or advantage of any description whatsoever, to any individual of external parties with whom they deal with in the course of the employment.

4.5 Anacle has clear guidelines with regard to the declaration of conflict of interest and the receipt of corporate gifts and any other benefits from our business partners which our employees are obliged to adhere to.

4.6 Anacle has an internal reporting structure, procedures and channels that are secure and accessible for our employees to raise concerns and report violations or suspicious activity.

4.7 If our employees are established to have been involved in prohibited practices, they may be subjected to disciplinary actions, including immediate dismissal of employment and/or referral to relevant law enforcement authorities.