Corporate Anti-bribery Policy V1.0
xFusion Digital Technologies Co., Ltd (hereinafter as xFusion or the company) complies with applicable laws and regulations in countries and regions where the company operates, and under the legal frameworks of fair competition, anti-bribery, and anti-corruption, places the commitment to anti-bribery and anti-corruption above our business interests, and operates with fairness, integrity while abiding by law and regulations.
xFusion is committed to establishing a compliance management system that aligns with industry best practices, and incorporating compliance management into end-to-end business activities and processes. xFusion will continue cultivating a culture of integrity and requires that all employees adhere to the Employee Business Conduct Guidelines. All xFusion employees, as well as entities and individuals who do business with xFusion, are required to comply with and uphold xFusion's anti-bribery and anti-corruption policies.
xFusion does not allow the provision of money or anything of value, driven by a corrupt intent, to public officials, counterparty stakeholders or stakeholders that can exert influence over a transaction for the purpose of obtaining or retaining business, or securing any other improper advantage. xFusion forbids its employees from taking bribes or soliciting gifts or other benefits directly or indirectly. For details, see Employee Business Conduct Guidelines.
The public officials mentioned above include individuals who perform duties on behalf of government entities; employees of government agencies, state-owned or state-controlled enterprises, or international organizations; members or candidates of political parties, and other personnel who perform public services according to the law. When engaging with public officials, xFusion employees must be mindful of adhering to applicable laws, honesty and integrity requirements for public officials, and xFusion's anti-bribery policy.
1. Gifts and hospitality
Under no circumstances should xFusion employees, motivated by a corrupt intent, be allowed to directly or indirectly offer gifts or hospitality to public officials, customers, or partners, or solicit gifts or hospitality from partners. Laws vary widely from country to country. Different customers also have very different regulations. xFusion employees must always bear in mind the company's anti-bribery policy and evaluate if the company's reputation will be affected when giving or accepting gifts and hospitality.
Make sure the following requirements are met before giving or accepting gifts and hospitality:
2. Charitable contributions and donations
3. Third-party management
Third parties include service providers, suppliers, downstream dealers, agents, consultants, and other partners. Cooperation between xFusion and third parties must be authentic and legitimate. xFusion requires its partners to comply with the Anti-corruption Policy for xFusion Partners, principles of honesty and integrity, and this policy.
4. Books and records
5. Consultation and report
"xFusion" in this policy refers to xFusion Digital Technologies Co., Ltd and its directly-or indirectly-controlled subsidiaries worldwide.
In the event there is any inconsistency between this policy and local laws and regulations, whichever has stricter requirements shall prevail.
This document takes effect since its issue date, and will remain valid for 3 years.