Anti-Bribery and Anti-Corruption Policy

True Internet Data Center Company Limited and its Subsidiaries

True Internet Data Center Company Limited (“Company” or “TIDC”) and its subsidiaries are committed to conducting business with integrity, transparency, and in compliance with the principles of good corporate governance. The Company strictly prohibits all forms of bribery and corruption and is committed to conducting business ethically and in compliance with applicable laws and codes of conduct.

To ensure clear understanding among customers, partners, business associates, public agencies, and all stakeholders, the Company sets forth the following key principles:

1. Giving and Receiving Gifts or Other Benefits
  1. Directors, executives, and employees of TIDC must not give or accept any gifts or benefits that may influence business decisions or lead to conflicts of interest.
  2. Gifts in the form of cash or cash equivalents (e.g. gift cards, vouchers), or items deemed inappropriate or illegal under applicable laws, are strictly prohibited.
  3. In exceptional cases, the giving or receiving of gifts must be conducted through a proper internal approval process and recorded in accordance with the Company’s internal procedures.
  4. The Company respectfully requests that all external parties refrain from offering any gifts or benefits to its employees, executives, or representatives under any circumstances.
2. Business Hospitality and Entertainment
  1. Business hospitality or entertainment is allowed only if it is appropriate, customary in business contexts, and does not influence or appear to influence business decisions.
  2. Attendance by Company personnel in such activities must follow the Company’s internal approval process and be properly documented.
3. Facilitation Payments
  1. The Company strictly prohibits all forms of facilitation payments, whether direct or indirect, including payments to government officials or any third parties to expedite or secure routine actions.
4. Charitable Donations and Sponsorships
  1. All charitable donations and sponsorships must be transparent, auditable, and must not be used as a means to improperly influence business decisions.
  2. Such donations must be approved through internal procedures and made only to legitimate, verifiable entities or individuals.
5. Representatives and Third Parties Acting on Behalf of the Company
  1. Any person or entity engaged to act on behalf of the Company (including agents, consultants, or representatives) must comply with this Policy as if they were employees of the Company.
  2. If a partner or counterparty has an anti-corruption policy, TIDC is willing to cooperate and align with such practices to the extent appropriate and mutually agreed.
6. Political Contributions
  1. The Company maintains political neutrality and does not support any political party or group.
  2. Any political activity involving the Company must be lawful, transparent, and not result in any conflict of interest.
7. Whistleblowing
  1. The Company encourages all stakeholders, including employees, partners, and external parties, to report suspected misconduct or violations of this Policy in good faith.
  2. Whistleblowers will be protected, and their identity will be kept confidential in accordance with the Company’s internal procedures.