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:

  • Proper intent: The purpose should be to establish and maintain a good business relationship. Gifts and hospitality should not be used to obtain or retain business, secure any other improper advantage, or influence general business processes or decisions.
  • Right timing: Avoid giving or accepting gifts and hospitality during sensitive periods, such as during a bidding process or before an important decision is to be made, as giving or accepting gifts and hospitality at such times may unfairly influence decision making.
  • Reasonable value: Comply with common business practices and do not give or accept excessively generous gifts, cash, or cash equivalents. Do not give or accept other types of prohibited gifts.
  • Compliance with laws and regulations: Give or accept gifts and hospitality openly and transparently in compliance with applicable local laws and the anti-bribery regulations of the other party.

2. Charitable contributions and donations

  • xFusion is committed to fulfilling its social responsibilities rather than blindly maximizing commercial interests and scale.
  • It is forbidden to use charitable contributions and donations to disguise corrupt activities. Effective measures must be taken to ensure transparency and legitimacy in making charitable contributions and donations.
  • xFusion does not directly-or indirectly-participate in the political activities of any political party, nor does xFusion sponsor local political parties, their candidates, associated persons, or affiliates.

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.

  • xFusion believes that due diligence, complete agreement clauses, and corresponding control procedures are key measures for ensuring that third parties comply with xFusion's anti-bribery policy.
  • It is forbidden to utilize, aid, abet or conspire with a third party to engage in bribery.
  • Third parties are forbidden from paying bribes on behalf of xFusion or when working with xFusion in any capacity. This prohibition includes bribes in the form of gifts or hospitality offered to xFusion employees, when the gift or hospitality offered does not comply with common business practices.

4. Books and records

  • At xFusion, appropriate documents should be provided in a transparent and honest manner to support business decisions and archived as required.
  • xFusion requires that all financial expenditures and assets disposed of be recorded in account books and financial records in an authentic, complete, and accurate manner in line with the document retention policy, to facilitate future inspection.
  • It is prohibited to set up off-the-record funds.

5. Consultation and report

  • If you have any questions about this policy, please consult your direct supervisor. If you still have questions, consult the compliance officer of your business domain and anti-corruption and bribery management officer; if you still have unanswered questions, consult the legal department;
  • If you know of or suspect a violation of this policy, please notify us by writing to
  • xFusion will launch investigations and protect the whistleblower from threats or retaliation by keeping his or her identification secret.

"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.