This policy aims to explicitly prohibit any form of bribery, corruption, and transfer of benefits, ensuring that all employees, partners, and third parties comply with laws, regulations, and ethical standards in their business activities. The scope of application includes:

• All employees, management, and board members of the company
• Suppliers, contractors, agents, and other business partners
• All transactions and activities related to the company's business

We are committed to:

1. The zero-tolerance principle
   prohibits directly or indirectly offering, accepting, soliciting or authorizing any form of bribery or corruption, including cash, gifts, entertainment, kickbacks and other improper benefits.

2. Compliance
   Comply with international regulations such as the Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act (UKBA), as well as the anti-corruption laws of the countries in which we operate.

3. Transparency & Accountability
   Ensure that all transaction records are true, complete, and traceable, and eliminate "off-the-books" or false financial practices.

Prohibited Conduct

• Bribery: Offering improper benefits to a public official or private entity for the purpose of obtaining a commercial advantage.

• Corruption: Abuse of power for personal gain, including manipulation of tenders, falsification of documents, concealment of conflicts of interest, etc.

• Facilitation Payments: Small fees paid to expedite the regular administrative process (even though common in some regions and expressly prohibited by the Company).

High-risk scenarios

• Government approval, license application

• Procurement bidding and contract signing

• Cross-border business, cooperation with high-risk areas

1. Avoid conflicts
   of interest and declare personal or relative's business-related financial interests in a timely manner.

2. Gifts & Entertainment
   Following the principles of "moderation, transparency, and legality", gifts or extravagant entertainment with a single value exceeding [XX amount] are prohibited.

3. Reporting Obligations When
   you become aware of suspicious behavior, report it immediately through the following channels:
   • Directly under the supervisor or compliance department
   • Anonymous Reporting Hotline: admin@globuydirect.com

1. Training & Advocacy
   • Annual anti-bribery training for all employees
   • Special training for high-risk positions (such as procurement, sales).
2. Due diligence
   • Conduct background checks on third-party partners and sign the Anti-Corruption Pledge.
3. Audit & Monitoring
   • Regularly review financial records, contracts, and transaction processes.

• Internal penalties: warning, suspension, dismissal, recovery of damages.

• Legal liability: transfer to the judicial authorities to bear civil or criminal liability.

• Reputational risk: Public notification and removal from the blacklist of partners.