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Anti-Bribery and Anti-Corruption Policy

  2. This Policy is intended to provide a level of awareness regarding applicable ABC Laws and is intended to make you aware of their prohibitions so that you can recognize potential problems and address them appropriately.

    A violation of ABC Laws can lead to severe civil and criminal penalties, including jail time, as well as reputational harm to the Company. A violation of this Policy could result in disciplinary actions, including termination of your employment and/or association with the Company. It is therefore vital that you not only understand and appreciate the importance of this Policy, but also comply with it in your day-to-day business activities.

  4. This Policy applies to all officers, directors and employees (collectively, “Personnel”) of Chuanjun Information Technology (Beijing) Co., Limited and its direct and indirect wholly owned and controlled subsidiaries (hereafter the “Company” or “Chuanjun”). This Policy is based on national and internationally accepted best practices and is applicable to the Company’s operations.

    This Policy reflects the standards the Company expects any person or entity that performs services for or on behalf of the Company to adhere to when acting on the Company’s behalf. Such persons or entities acting on the Company’s behalf could include business associates, partners, consultants, agents, intermediaries, representatives, suppliers, contractors, and certain third-party service providers
    (collectively “Third Parties”).

  6. The Company is committed to conducting business in accordance with the highest ethical standards and has a zero tolerance for unethical business conduct. Chuanjun prohibits all forms of bribery and corruption, including the offering, promising, authorizing, or providing anything of value to any customer, business partner, vendor or other third party to induce or reward the improper performance of an activity connected with our business.

    1. Bribery and corruption are strictly prohibited.
    2. To reiterate, the Company strictly prohibits bribery or corruption in any form whatsoever.

      Personnel and Third Parties are prohibited from giving or offering bribes, kickbacks, or similar payment or consideration of any kind, whether at home or abroad, to any person or entity (including but not limited to any customers or potential customers, government official, political party, candidate for political office or any intermediaries, such as agents, attorneys or consultants) in order to influence official acts or decisions of that person or entity, obtain or retain business for, or direct business to, the Company; and/or secure any improper advantage.

      A “bribe” is anything of value that is offered, promised, given, or received by any party to influence a decision or to gain or reward an improper or unfair advantage for the benefit of the Company. “Corruption” is the willingness to act dishonestly in return for money or other personal gain. Bribery and corruption can take many forms, including the offering, provision, or acceptance of:

      1. ⊗ Cash payments.
      2. ⊗ non-arm’s length transactions.
      3. ⊗ Sham jobs or “consulting” relationships.
      4. ⊗ Kickbacks.
      5. ⊗ Political and/or charitable contributions.
      6. ⊗ Gifts, travel, hospitality, and the reimbursement of expenses.

      It is important to note that a bribe does necessarily need to involve cash or an actual payment exchanging hands but can take many forms such as an expensive gift, lavish treatment during a business trip or tickets to a hospitality event.


      Did you know? ABC Laws do not just apply to the person who pays the bribe or offers anything of value – they also apply to the people who have acted in furtherance of the same. For example, ABC Laws could apply to anyone who:

      ✔  approves the payment.
      ✔  creates or accepts false invoices.
      ✔  relays email instructions to pay or accept a bribe or kickback.
      ✔  covers up an illegal payment.
      ✔  knowingly cooperates in the payment of a bribe, or
      ✔  is aware of, but turns a “blind eye”, towards an illegal payment or kickback.


    3. Do not make “facilitation payments.”
    4. The making of ‘facilitation payments’ either directly or indirectly through agents, contractors or intermediaries by Personnel and Third Parties is prohibited. Facilitation payments are small payments made to secure or speed up routine actions or otherwise induce public officials or other Third Parties to perform routine functions they are otherwise obligated to perform, such as issuing permits, approving immigration documents, or releasing goods held in customs. This does not include legally required administrative fees or legally permitted fees to fast-track services.
      If you have a question about whether a particular payment is permitted under this Policy, please contact the General Manager prior to making such payment.

    5. Gifts, Meals and Entertainment
    6. A prohibition on bribery may sound easy and obvious. However, knowing when a friendly business gesture crosses the line into bribery may be difficult in real-world situations. The Company acknowledges that giving and receiving nominal benefits (such as gifts, meals, and entertainment) is a common business practice and is intended to strengthen and build long term business relationships.
      Giving or receiving benefits is appropriate, proper, and legitimate if the benefit in question is:

      1. bona fide.
      2. moderate and reasonable.
      3. infrequent in occurrence,
      4. appropriate in nature.
      5. transparent and open.
      6. given for a legitimate purpose (related to work or business).
      7. consistent with customary practice.
      8. in compliance with applicable laws.

      A benefit is not appropriate, proper, and legitimate if it is given in cash, cash equivalents (gift certificates, coupons), items readily convertible into cash (jewelry, stocks, stock options) or contributions to political parties or political candidates.
      Personnel and Third Parties are prohibited from providing gifts, meals, entertainment, or anything of value to any person or entity in connection with Company business unless it is provided in accordance with:

      1. this Policy,
      2. the Company’s Business Code of Conduct, and
      3. the Company’s other applicable Policies and Procedures.


  8. Interactions with public officials require enhanced scrutiny and sensitivity.

    While it is the Company’s policy to prohibit paying of bribes to anyone, some ABC Laws primarily apply to payments to government officials. There is increased sensitivity of dealings with government officials because it is an area where bribery activity and corruption are more likely to occur.

    Be aware of these risks in any dealings and interactions with public officials and consider how your actions may be viewed. For example, payments, gifts, or offering employment to close relatives of public officials can be treated by enforcement authorities as direct payments to the public officials and, therefore, may constitute violations of applicable ABC Laws.

    In addition, because interactions with public officials carry special risks under applicable ABC Laws, contracts and payments to public officials should be reviewed carefully to determine what additional safeguards, if any, may be necessary to protect the Company.

    Please seek authorization from the General Manager prior to entertaining, contracting with, or offering or extending any benefits or payments to public officials.

  10. Do not offer contributions to political parties or candidates that might influence, or be perceived as influencing, a business decision.

    It is the Company’s policy that under no circumstances shall Company funds be used to make political contributions to political parties or candidates in any country, even if such contributions are permitted by a country’s written laws or regulations. It must be clearly understood that no employee in the Company can therefore make any sort of political contribution from Company funds under any circumstances whatsoever.

    The Company’s policy is not intended to discourage or prohibit employees of a country from voluntarily making personal political contributions, from participating in the political process on their own time and at their own expense, from expressing their personal views on legislative or political matters, or from otherwise personally engaging in political activities in such country.

  12. Do not solicit or offer donations to suppliers, vendors, or public officials if it is a prerequisite for future business or if the offer of a donation is intended to obtain a business advantage.

    We encourage our Personnel to contribute personal time and resources to charities and nonprofit organizations. Charitable donations or requests for charitable donations made by individuals on their own behalf should comply with any applicable local laws and regulations. If you are requested by a public official to make a personal donation to a particular charity, please seek authorization from the General Manager before agreeing to or making the donation.

    The Company also believes in contributing to the communities in which it does business and permits reasonable donations to charities, however, it needs to be certain that donations to charities are not disguised illegal payments to government officials in violation of ABC Laws. The Company also needs to confirm that the charity does not act as a conduit to fund illegal activities in violation of anti-money laundering laws or anti-terrorism laws. It is therefore the Company’s policy that, unless the solicitation is supported by the Company in writing, Personnel are prohibited from using the Company’s resources to solicit donations.

    All requests on behalf of the Company for corporate gifts to charities and other not-for-profit organizations must be authorized in advance.

  14. Do not solicit or offer to make social contribution payments, whether within or outside of a contractual agreement to do so, without first seeking approval.

    Certain agreements may require the Company to make payments to assist with the development of a particular country. These payments may be charitable donations and training obligations, or social contribution payments. The Company may also wish to make development related payments outside of a contractual obligation. Whether within or outside of a contract, these types of payments must be reviewed for compliance with applicable ABC Laws, and approval of any such payment must be obtained prior to agreeing to
    make the payment.

    Neither the existence of a contractual obligation nor the legality of the payment under any applicable local laws or regulations shields the Company from liability under certain ABC Laws.

  16. Record all our transactions in a complete, accurate and detailed manner so that the purpose and amount of the transaction are clear.

    In addition to prohibiting bribery and corruption, some ABC Laws require proper record-keeping and the establishment and maintenance of internal controls. The purpose of these provisions is to prevent companies from concealing bribes and to discourage fraudulent accounting practices. All the Company’s transactions must be recorded completely, accurately and with sufficient detail so that the purpose and amount of any payment is clear. No accounts or payments may be kept “off-book”. False, misleading, or artificial entries must never be made in the books and records of the Company for any

    It is the Company’s policy that it will maintain books and records practices and internal controls so as to ensure that: (i) receipts and expenses are accurately recorded with reasonable detail and are based on accurate and sufficient supporting documentation; and (ii) no “off the books” accounts are created or maintained, and it is also the Company’s policy that such books and records will be maintained for seven (7) years after the consummation, termination, or expiration of any applicable transaction.


    Did you know? Examples of improper record-keeping include, but are not limited to:
    ✔  making records appear to show a payment to one person when, in fact, the payment was made to someone else
    ✔  creating a “slush fund”; submitting false or inaccurate expense account reports, and
    ✔  creating records that inaccurately characterize the true nature of a transaction or payment (for example, reporting an “overhead expense” instead of “commission”).


  18. Third Parties are not permitted to pay, offer, accept, or request bribes on our behalf.

    The Company recognizes that there are circumstances in which relationships with third parties such as channel partners will be required or prudent from a commercial perspective, however, public corruption often occurs when companies use third parties as intermediaries to obtain business or influence action on their behalf. Further, ABC Laws do not always differentiate between acts made by you or by someone acting on your behalf. As such, the Company can face liability under anti-corruption laws based on improper payments made by its agents, consultants, channel partners, resellers, or other business partners, regardless of whether the Company had direct knowledge of the improper payments.

    For this reason, we need to be certain that we only deal with third party intermediaries who are prepared to apply the same standards of business conduct as the Company does itself.

    The Company performs appropriate due diligence on certain engagements, including with respect to any Third Parties acting on the Company’s behalf, in accordance with its Third Parties Due Diligence Policy. The Company will perform appropriate due diligence on the engagement of any Third Parties providing service in or headquartered in jurisdictions with a Corruption Perceptions Index (“CPI”) score of 50 or lower.

    Further, certain undertakings with Third Parties may be subject to due diligence, or on a particular engagement if directed by the Company after reviewing the engagement pursuant to the Third Party Due Diligence Policy. Due diligence may include informing these Third Parties (and associated companies) of this Policy, meeting with them to better assess their character, making commercially reasonable inquiries into their reputation and past conduct, conducting background screenings and watch list checks, and obtaining compliance certifications from the Third Party. Anti-bribery language will be included in Third Party agreements, where appropriate, in consultation with legal counsel and in accordance with the Company’s Contracting Guidelines.

    1 The CPI ranks countries/territories based on how corrupt their public sector is perceived to be. It is a composite index, a combination of polls, drawing on corruption-related data collected by a variety of reputable institutions. The CPI reflects the views of observers from around the world, including experts living and working in the countries/territories evaluated. A country/territory’s score indicates the perceived level of public sector corruption there on a scale of 0 – 100, where 0 means that a country is perceived as highly corrupt and 100 means that a country is perceived as very clean. A country’s rank indicates its position relative to the other countries and territories included in the index, and the 2021 index includes 180 countries and territories, with the number 1 representing the least corrupt country and number 180 representing the most corrupt country in the index.


    Did you know? You may never do through any third party what you may not do directly. Authorizing or encouraging any third-party, including a distributor, reseller, or channel partner to pay bribes or engage in other misconduct is a violation of Company Policy and Anti-Corruption Laws. Even the knowledge of an improper payment or illegal activity can lead to civil and criminal liability against the Company and quite possibly for the individual with knowledge.


  20. The Company’s Personnel and Third Parties have an obligation to adhere to this Policy. If you witness behavior on the part of any Personnel or Third Party that you believe may represent a violation of this Policy, you must promptly report it. Internal reporting is important to the Company and it is both expected and valued. The Company takes all reports seriously, and every report received will be assessed and, where necessary, appropriate investigation will be undertaken. The confidentiality of reported violations will be maintained where possible, consistent with the need to conduct an adequate
    review and subject to applicable law.

    Reports should in the first instance be made through the reporting channels in the Company’s Whistleblower Policy. No retribution or retaliation will be taken against any person who has made a report based on the reasonable, good faith belief that a violation of this Policy has occurred.

  22. Company policy requires all Personnel and certain Third Parties to take and pass the Company’s anticorruption training course/s which will be rolled out by the Company from time to time. The course/s may be conducted on-line or in-person.

    Each Personnel or Third-Party will be notified via email that they are required to take the course/s. Those required to take such course/s must do so within the notified timeframe and to repeat the course/s as and when required. Failure to do so without justification will be viewed very seriously by the Company and could result in the withholding of any discretionary bonus payment, suspension and/or termination of your employment and/or association with the Company.

  24. In furtherance of this Policy, the Company will conduct periodic, confidential audits. Our management team will determine the frequency and scope of any periodic audit. These periodic audits are designed to prevent and detect violations of the applicable ABC Laws, this Policy and other Company policies.

    The audits will focus on the following items:

    1. Strategy to ensure compliance with applicable ABC Laws;
    2. Communication with and education of Personnel and relevant Third Parties;
    3. Establishment and implementation of monitoring mechanisms;
    4. Due diligence procedures taken prior to entering into arrangements with Third Parties; and
    5. Review of a random sample of the Company’s business agreements.
    6. The periodic audits will also include a review of the Company’s books and records pertaining to the relevant expenditures (gifts, meals, entertainment, travel, donations, etc.) by Personnel and Third Parties on behalf of the Company.
  26. In addition to the periodic audits described above, there may also be individual instances in which the Company may wish to investigate a certain matter. In these events, the General Manager, in consultation with outside legal counsel, may perform an investigation of the Company’s records, books and accounts, and any other evidence required under the circumstances to prevent and detect violations of applicable ABC Laws and to ensure compliance with this Policy and other Company policies.

  28. The Company will impose discipline on individuals found to have breached this Policy, in a manner that is fair, consistent and that reflects the nature and facts of the violation. Anyone subject to this Policy who violates it may face disciplinary actions up to and including termination of his or her employment or relationship with the Company for cause and without notice. The violation of this Policy may also violate certain ABC Laws. If the Company discovers a violation of any ABC Law, it may refer the matter to the appropriate authorities, which could lead to penalties, fines or imprisonment or other liability.