Announcement of Anti-Corruption Policy

True Internet Data Center Company Limited (“the Company”) and its subsidiaries (collectively referred to as “True IDC”) is committed to conducting its business with transparency, integrity, and in full compliance with applicable laws and ethical standards. This Policy is established to promote good corporate governance, support sustainable and efficient business operations, and enhance confidence among customers, business partners, and other stakeholders.

True IDC fosters an organizational culture that does not tolerate corruption in any form through effective communication, training, and awareness programs. These initiatives are designed to ensure that directors, management, and staff understand and comply with this Policy in a consistent and effective manner.

True IDC encourages employees and stakeholders to report any suspected corruption and to cooperate fully in fair and impartial investigations, to maintain a transparent, trustworthy, and safe working environment for all.

• All business processes must be transparent and auditable to prevent corruption.
• Directors, management, and staff must comply with applicable laws and the Anti-Corruption Policy.
• True IDC promotes active participation in corruption prevention, whistleblowing, and the development of a zero-tolerance culture toward corruption.
• True IDC maintains effective internal control systems to prevent and mitigate corruption risks.
• True IDC conducts regular reviews and assessments of compliance with this Policy at least once per year.

• Directors, management, and staff at all levels must strictly comply with the Anti-Corruption Policy and must not engage in, accept, or support any form of corruption, whether directly or indirectly, including the giving or receiving of money, gifts, entertainment, donations, political contributions, support to government entities, or any other improper benefits.
• All business units must implement appropriate anti-corruption controls in line with applicable policies, procedures, and laws, including conducting periodic corruption risk assessments and continuously improving systems and controls to reflect business changes.
• Employees must not ignore any conduct that may constitute corruption and must report concerns through supervisors or designated reporting channels. Any questions regarding policy interpretation should be escalated to supervisors or relevant functions.
• True IDC provides whistleblowing channels for employees and external parties and ensures protection for good-faith reporters and individuals who refuse to engage in corruption, against retaliation, punishment, or unfair treatment in any form.
• True IDC will not demote, penalize, or take any adverse action against personnel who refuse to give bribes, even if such refusal may result in the loss of business opportunities.
• True IDC will continuously communicate and disclose its Anti-Corruption Policy through appropriate channels and provide regular training to employees.
• True IDC encourages business partners, external stakeholders, agents, and suppliers to acknowledge and comply with anti-corruption principles to uphold ethical standards throughout the business value chain.
• True IDC enforces a no-gift policy during New Year and other special occasions and prohibits facilitation payments in any form, whether directly or indirectly.
• Employees must perform their duties with integrity, transparency, and in compliance with applicable laws, the Company’s policies, the Code of Conduct, and internal regulations.
• True IDC supports and cooperates with private sector organizations, government agencies, and civil society, both domestically and internationally, to combat corruption and to promote awareness across employees and external stakeholders throughout the supply chain.
• True IDC will report on the implementation of its anti-corruption policies, practices, and control measures as required.