Hymson has always attached great importance to enterprise compliance and honest operation, and is committed to conducting business on the basis of fairness, impartiality, and openness. In the process of conducting business both domestically and overseas, Hymson adheres to the applicable anti-corruption and anti-bribery laws and regulations of various countries, and firmly opposes any form of corruption and bribery.

This Hymson Third Party Partner Management Compliance Policy (hereinafter referred to as "Third Party Management Policy") applies to Hymson Technology Group Co., Ltd. and its domestic and foreign controlling subsidiaries, affiliated companies, and various branches (hereinafter collectively referred to as "Hymson"), as well as all its Third Party partners, including suppliers, distributors, agents, contractors, consultants and any other Third Party acting on behalf of the Company, as well as subcontractors hired to perform work on behalf of Hymson (hereinafter collectively referred to as "Third Party"). If this Third Party Management Policy is inconsistent with local laws and regulations, the more stringent requirements shall prevail.

Hymson prohibits any Third Party from bribing influential public officials or private enterprise personnel and their families. Naturally, Hymson also prohibits its employees from using Third Party for bribery. Correspondingly, Hymson also requires Third Party not to bribe Hymson employees. Regarding what constitutes "bribery"; please refer to the Hymson Anti-Corruption and An-Bribery Policy.

Due Diligence

For any Third Party that may interact with public officials or government departments on behalf of Hymson, before establishing a relationship with such Third Party, it is necessary to conduct due diligence on Hymson and, to the satisfaction of Hymson's [Procurement Department], resolve any "dangerous signals" that may arise during the due diligence review of suppliers (see below) and record any remedial measures taken. Hymson insists on conducting regular due diligence on active suppliers.

Written Contract

Hymson requires Third Party to comply with all applicable anti-corruption and anti-bribery laws and regulations, comply with local industry and social ethical standards, learn and comply with the relevant requirements stipulated in the Hymson Anti-Corruption and Anti-Bribery Policy, Third Party Management Policy, and other agreements signed with Hymson.

Hymson insists on allocating their respective rights and obligations with Third Party through written agreements, clarifying the services or products they provide, as well as the corresponding amounts and payment methods, in a way that can be recorded and consulted. The [Legal and Compliance Department] will review and approve such agreements. Without approval, no cooperation with Third Party is allowed. Such agreements shall include appropriate anti-bribery provisions.

After the formal cooperation, relevant personnel of Hymson shall monitor the activities and expenses of Third Party to ensure their continuous compliance with applicable anti-corruption laws and Company policies. Any and all payments made to Third Party, including commissions, compensation, and reimbursements must be customary and reasonable payments directly related to the services or products provided, and shall be truthfully, accurately, and completely recorded in the Company's books and records. No undisclosed or unrecorded accounts shall be established or used. However, payment to Third Party in cash is not allowed. Payment shall not be made to accounts other than the bank account specified in the agreement with Third Party or through other channels not included in the agreement.

Dangerous Signals

The following dangerous signals represent that Third Party may be engaged in or will be engaged in activities that violate anti-corruption and anti-bribery laws and regulations or relevant policies of Hymson:

1.  Third Party capability: Third Party does not possess qualifications or experience that match the products or services it intends to provide, and is unable to provide supporting materials; Third Party highly relies on government funding or subsidies; There is no Third Party anti-corruption compliance system or measures in place;

2.  Background of the Third Party: The Third Party has close personal or business relationships with Project related public officials (such as having previously employed or currently employing public officials or their close relatives); Public officials request, suggest, designate or recommend Hymson to hire a specific Third Party, and cannot provide a reasonable basis for such intention; Third Party refuses to disclose its shareholder, partner, or principal identities, including using shell companies, offshore companies, or using holding companies or other methods to conceal its ownership without legitimate business reasons;

3.  Negative news: Third Party has had or are currently facing litigation, arbitration, and other disputes related to corruption and bribery, or there are related negative reports; Third Party has been or is being accused of violating anti-corruption and anti-bribery laws and regulations;

4.  Abnormal payment requests: Third Party payment requests do not comply with the relevant Contract provisions signed with Hymson or violate industry practices. In the absence of normal business reasons, Third Party demands high invoices or advance payments when there is no Contract agreement: the commission required by Third Party significantly exceeds general industry practices; Third Party requests payment to be made to an account other than the bank account specified in the agreement with the Third Party or through other means not included in the agreement; Third Party requests direct cash payment; Third Party requests payment in multiple currencies or funds that are difficult to track; Third Party requests for political or charitable donation;

5.  Other suspicious behaviors: Third Party refuses or is unwilling to make a written commitment to comply with Hymson's anti-corruption compliance policies and applicable relevant laws and regulations; Third Party provides forged or untrue document materials; Third Party wishes Hymson to keep confidential the services it provides to the Company or its employment terms.

Consultation and Reporting

All employees of Hymson and other Third Party related personnel shall comply with applicable anti-corruption and anti-bribery laws and regulations, as well as this Hymson anti-corruption compliance policy. Those who fail to comply with this anti-corruption compliance policy will be punished in accordance with the Company's regulations and policies, such as the Management Measures for Punishment of Employee Violations. Severe cases may include termination of employment, deduction of all bonuses, severe warnings, and termination of business relationships. If you have any questions about this anti-corruption compliance policy, please feel free to consult the [Supervision Department] through [Email].

If you find anyone who is suspected or has violated this policy, please report it through the following channels:

Hymson will take it seriously and conduct necessary investigations into the relevant reports. Hymson welcomes and encourages anyone to actively report illegal and disciplinary behavior, and will strictly keep the identity of the informant confidential. No one is allowed to threaten or retaliate against those who report potential compliance issues in good faith.