Anti-Bribery and Corruption Policy

1. Policy Statement

LFS Group Asia is committed to maintaining a corporate culture of integrity, high ethical standards, and zero tolerance for bribery and corruption. This policy reinforces our commitment to ethical conduct, ensuring fairness, honesty, and probity in all our operations. The company upholds Anti-Bribery and Anti-Corruption (ABAC) laws in all jurisdictions where it operates and aims to establish a robust ABAC control framework. All employees, as well as third parties engaged by the company, are strictly prohibited from engaging in any form of bribery, corruption, or unethical conduct.

2. Scope of Application

This policy applies to LFS Group Asia and all affiliated companies, Southeast Asian entities, and all individuals associated with the company, including full-time, part-time, and contract staff.

3. Definitions

– Corruption:

The abuse of entrusted power for private gain, involving any activity that improperly influences an individual’s function for personal or business gain.

– Bribery:

Under the Prevention of Bribery Ordinance (“POBO”) of Hong Kong, bribery involves offering any advantage to a public servant or an agent to improperly influence their function at work.

– Advantage:

Anything of value offered, such as gifts, loans, fees, rewards, commissions, facilitation payments, services, employment, or promises of such.

4. Management and Monitoring

The ABAC framework is jointly supervised by the Board of Directors, its designated committee, and senior management to ensure proper management and implementation.

5. ABAC Principles and Requirements

5.1. General Prohibitions:

• No employee should offer, promise, give, authorize, solicit, or accept any advantages for improper influence, business advantage, or dishonest acts.
• Conduct business with fairness, impartiality, openness, and transparency, strictly complying with all laws and regulations.
• Avoid situations that may cause conflicts of interest, promptly reporting unavoidable conflicts to supervisors.

5.2. Key Areas of ABAC:

• Gifts and Entertainment: Maintain a register for gifts and entertainment, ensuring they are not lavish or inappropriate.
• Hiring and Workforce Appointment/Removal: Prohibit using employment opportunities for business advantage, avoid conflicts of interest in hiring decisions.
• Procurement: Conduct due diligence before engaging new vendors, include ABAC clauses in contracts.
• Credit Approval: Observe segregation of duties, declare conflicts of interest in the credit process.
• Charitable Donation: Ensure due diligence on beneficiary organizations before approving charitable donations.
• Third-Party Relationship: Perform due diligence before establishing relationships with third parties, terminate engagements if non-compliance is identified.

5.3. Consequences of Violations:

• Violations of this policy may lead to disciplinary actions, including dismissal. Serious offenses may constitute criminal acts, resulting in prosecution, fines, and imprisonment.

6. Control Mechanism

6.1. Regular Risk Assessment:

• Conduct regular ABAC risk assessments to identify and address potential control loopholes.

6.2. Reporting Bribery and Corruption:

• Employees should report any bribery or corruption incidents through designated channels.

6.3. Training and Signoff:

• Regular training covering ABAC laws, policy requirements, and case studies is mandatory for all employees. Staff must sign off for acknowledgment of understanding.

6.4. Record Keeping:

• Maintain accurate books and records, and document all payments to third parties with clear descriptions. Properly document acceptance and provision of gifts and entertainment.

6.5. Review and Amendment:

• This policy is subject to annual review and amendment to ensure relevance and effectiveness, with approval from the Audit Committee.

This Policy is in effect and implemented with the approval of the Audit Committee, as authorized by the Board of Directors. The Group emphasizes the importance of reporting any bribery and corruption events, ensuring confidentiality, and prohibiting retaliation against individuals making genuine reports. All employees are responsible for completing mandatory ABAC training and staying updated on the company’s policies and processes.

Suspicions and/or allegations of potential breaches of the Anti-Bribery and Corruption Policy must be immediately reported to our compliance department at compliance@lfsgroupasia.com

Last Updated: 24 January 2024