DC Holdings has strict corporate governance and requires all employees to perform their duties with integrity, in an ethical and proper manner. The Company strictly abides by applicable laws and regulations in the jurisdictions where it operates. The term ‘employee’ in this Anti-Corruption Policy refers to any permanent, contract or temporary employee, secondee and director of the Company.

1. Prevention of Bribery Ordinance
   • The Company strictly prohibits any form of bribery or corruption.
   • Employees are required to perform their works with integrity, in an ethical and proper manner, and in compliance with all applicable laws and regulations of the jurisdictions in which the Company operates, including anti-bribery laws.
2. Soliciting & Accepting Advantages
   • Employees are strictly prohibited from soliciting any form of benefits from customers, suppliers, government officials or anyone else, related to the Company's business.
   • Under all circumstances, employees should actively refuse any form of bribes such as cash and cash equivalents, entertainment, valuables and borrowing of assets, etc. from anyone including working partners. Only souvenirs with symbolic value are excluded.
3. Offering Advantages
   • Employees are strictly prohibited from offering any advantages to customers, suppliers, government officials or anyone related to the Company's business, except for souvenirs of low value and only of symbolic value.
   • Offering free trips or reimbursing travelling expenses incurred that are directly for the purpose of promoting, demonstrating or certifying the Company’s business and service may be proper, with the prior consent of the Company.
4. Entertainment Employees may accept invitations to business lunches or dinners from business associates provided they are not unreasonably generous that may give rise to any potential or real conflicts of interest.
5. Training and Monitoring The Company conducts periodic internal monitoring and bribery and corruption risk assessments to ensure bribery and corrupt activities are prevented.

The Company will review the DC Holdings Anti-Corruption Policy from time to time in accordance with its corporate strategies and development on governance issues relating to its operations.