Anti-corruption policy-Notice-Xispek

Xispek is committed to eliminating corruption at all levels of our value chain, continuously raising awareness of anti-corruption among employees and suppliers at all levels, and ensuring that they conduct themselves in an ethical manner and perform their duties with fairness and integrity.
This guideline applies to all employees, including full-time, part-time and outsourced employees, as well as stakeholders who have business dealings with the Company and all its subsidiaries.
1. Bribery, Intercourse and Benefits
The Company strictly prohibits bribery and does not allow any employee to offer, solicit or accept bribes, including soliciting or offering any benefits to customers, suppliers, legislative and/or law enforcement units or others related to the Company's business; or acting as a third-party intermediary in order to offer, solicit or accept any benefits. It is a violation of this Code for any person, with or without the permission of a supervisor, to use his or her position to solicit or accept an advantage of any kind.
1.1 Offering Benefits:Under no circumstances shall an employee offer a bribe or improper benefit to any person or organization for personal gain or for the benefit of the Company.
1.2 Solicitation of Benefits:Employees shall not solicit, directly, indirectly, or in any form, any benefit from any organization or individual in connection with the Company's business.
1.3 Acceptance of Benefits:Employees shall not accept any benefit directly or indirectly related to the Company's business if such acceptance would impede their objective judgment and handling of the business in question, induce them to act contrary to or to the detriment of the Company's interests, result in violation of laws, regulations and the requirements of the Listing Site, give rise to a complaint of favoritism or impropriety, and/or cause the employee to feel the need to reciprocate to the giver in the business.
1.4 All behavior related to unbundling fees is prohibited.
2 Conflict of Interest
2.1 Definition of Conflict of Interest
Common conflict of interest situations include, but are not limited to, the following.
2.1.1 Undeclared financial interests/transactions with any supplier, service provider or related person doing business with the company.
2.1.2 Employing a service provider who is working or has worked for the Company to work or provide services, goods, etc. for himself/herself and/or immediate family members.
2.1.3 Providing special privileges to individual suppliers, service providers, customers, job applicants, subordinates or superiors for personal reasons.
2.1.4 Employees or their immediate family members (including parents, children and spouses) are engaging in or considering engaging in things, investments or activities that have a conflict of interest with the company or may lead to a conflict of interest.
2.1.5 To perform outside work within the Company, utilizing work time, Company assets (including human resources); and
2.1.6 Providing assistance to competitors of the Company; and
2.1.7 Privately providing or manufacturing services or goods that are in competition with the Company.
2.2 Declaration of Conflicts of Interest
Employees are expected to avoid actual or predictable personal conflicts of interest with the Company or to influence their judgment in the performance of their duties. Employees shall be required to declare all actual or predictable conflicts of interest in a timely manner.
2.2.1 If an employee realizes that a conflict of interest with the Company exists or may exist, he/she must immediately declare it in writing to his/her department head.
2.2.2 Failure to comply with the above requirements may result in severe disciplinary action, including demotion and dismissal.
3 Insider Trading
3.1 If an employee has any material information and/or price-sensitive non-public data about the Company or any other listed companies with which the Company has business dealings, the employee should not buy or sell any securities of the Company or such listed companies, or disclose the relevant information to others, before such data is made public.
3.2 Employees shall comply with all legal regulations regarding insider trading. Any employee involved in insider trading will be penalized or even dismissed in accordance with the relevant Company systems. At the same time, the Company will also report to the relevant law enforcement authorities.
4 Anti-Money Laundering
Money laundering is the use of otherwise legal business transactions to conceal the source of illegally obtained funds, usually involving payments in the form of cash or money orders. Suspicious activities include: large cash transactions and customers who are unwilling to provide verifiable information. We comply with applicable anti-money laundering laws and regulations. We do not tolerate, support or facilitate money laundering.
All employees are expected to
4.1 Pay attention to the compliance of payment methods.
4.2 If there are concerns about a payment, you need to report them to your supervisor.
4.3 If a transaction is suspicious, report the matter to the Legal Compliance Department even if the transaction does not continue.5 Anti-Undue Competition
In a free market system, competition drives efficiency and innovation. However, violating laws that protect competition can result in penalties including substantial fines, imprisonment, damage to reputation and exclusion from government contracts. We are committed to complying with anti-unfair competition/anti-trust laws and regulations wherever we operate to maintain a fair and orderly marketplace.
All employees are expected to.
5.1 Always refer to this Code when interacting with competitors.
5.2 Seek guidance from the Legal Compliance Department whenever anti-unfair competition/antitrust issues arise
5.3 Make full use of public information and the competitive environment for competitive activities.
5.4 Keep in mind that illegal and unethical behavior is not permissible under any circumstances.
5.5 Prohibit discussing with competitors any of the Company's competition-related terms, work, customers or prices
5.6 Prohibit discussing with competitors plans to submit bids or quotes for any particular project or customer
5.7 It is prohibited to talk to anyone about boycotting or rejecting certain suppliers or customers.
5.8 It is prohibited to take any action for the purpose of harming or retaliating against a competitor.
6 Illegal and Improper Payments
The Company and all of its employees shall not use property or other means to bribe for the sale of goods. Any person who secretly gives a kickback to the other company or individual off the books shall be punished as a bribe. If it is necessary to give discounts to the other party when selling services and goods, including but not limited to commissions to intermediaries, in-kind payments, etc., they must be given to the other party in an explicit manner, along with possible supporting documents, and the finance department must be notified of the fact that the payment has been duly recorded in the accounts.
7 Business Partners, Seiyoshi and Customers
7.1 Loading of goods and services
The Company guarantees fair dealings with our suppliers, fair competition in a competitive evaluation process to determine suppliers, without any discrimination or deception against suppliers, and the selection of suppliers shall be based on the price, service, quality and reputation provided by the suppliers, and based on the principle that it is beneficial to the Company's long-term business development. Employees are expected to remain impartial at all times in their relationships with suppliers and should not attempt to exert influence to obtain “special treatment” for a particular supplier, as this could jeopardize our competitive selection process. Employees should not accept or solicit personal benefits from suppliers and target vendors that would jeopardize the fairness of the evaluation of the supplier's products and prices. Employees are also expected to maintain the confidentiality of pricing or product information submitted to the company by suppliers or potential suppliers. Purchase agreements should be properly approved and specify the services and products to be provided, the basis for calculating payment, and the applicable prices and fees. Payment amounts must be commensurate with the services or products provided.
7.2 In-kind discount gifts
For in-kind discounted gifts provided by suppliers in the course of procurement negotiations with suppliers, in principle, they should be reflected in the procurement contract; for cases where there is no contract or where they cannot be reflected in the contract, the gifts should likewise be regarded as the company's assets rather than personal gifts of the employees involved in the negotiations.
7.3 Interaction with Prospects and Customers
The Company is committed to meeting all of the needs of its customers, to customer satisfaction and to maintaining long-term partnerships with its customers. Employees shall not knowingly misrepresent the Company's or a competitor's products or services to customers; all comparisons with competitors must be accurate, based on publicly available information and not misleading. Employees may not enter into side agreements or private agreements with customers outside of a written contract. Employees may not offer money or any other form of bribe, directly or indirectly, to government officials in order to obtain or retain customers.
8 Donation Behavior
Donations and sponsorships may be used to conceal improper benefits and may constitute direct or indirect corrupt practices. This risk is more pronounced when public officials are directly or indirectly associated with activities that benefit from donations and sponsorships. Therefore, all donations and sponsorships by the Company must be subject to an appropriate approval process, the rigor of which should increase with the value of the donation, particularly where the potential beneficiaries of the donations and sponsorships are public officials or have links to the Company's customers, governments, or political figures.

9 Requirements for Suppliers
The Company implements the sunshine procurement model of “fairness, openness and impartiality”, and continuously improves the transparency of procurement by strictly enforcing the bidding procedures and expanding the scope of price search. When signing contracts with suppliers, the Company's departments and subsidiaries shall send integrity notification letters or sign integrity commitment letters and integrity contracts to the relevant parties, including clauses prohibiting the provision of all kinds of benefits and facilities to the Company's staff members, their relatives and specific related persons by the cooperative parties. At the same time, as a one-vote veto system, suppliers will not be allowed to participate in bidding and will be included in the blacklist if any violation occurs. Please refer to the Company's Supplier Code of Conduct for more details on the anti-corruption requirements for suppliers.