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ANTI-BRIBERY POLICY

Purpose

The purpose of this policy is to ensure that all Vnohow employees and representatives conduct all businesses in an honest, ethical and professional manner and “understand and adhere” to this Anti-Bribery Policy.

Scope

This Anti-Bribery Policy applies to all Vnohow employees and representatives who work at any level, including those of wholly and majority-owned entity of Vnohow.

Policy Statement

Bribery occurs when an individual or entity offers, pays or receives money, bribes, gifts or any other benefits to or from third parties to influence business results or personal interests. Bribery is not permitted at Vnohow as it is against our company values and is considered unethical, illegal and harmful to the company reputation for honesty and integrity. Vnohow has committed to conduct all businesses in an honest, ethical and professional manner in compliance with applicable laws and regulations and will not influence others by offering, paying or receiving money, bribes, gifts or other benefits either directly or indirectly. All employees and representatives are expected to turn down any opportunity that could damage the reputation of the company and avoid any activities or events that could be construed as bribery. All employees and representatives are anticipated to report any actual or suspected violations of the Anti-Bribery Policy.