Introduction:

H.S Cool Point is committed to conducting its business with the highest ethical standards and in full compliance with all applicable laws and regulations. This policy sets forth our company’s comprehensive approach to preventing, detecting, and responding to corruption in any form.

Definition of Corruption:

Corruption encompasses any act that constitutes the misuse of entrusted power for private gain or improper benefit. It includes, but is not limited to:

• • Bribery: Offering, promising, or giving bribes, directly or indirectly, to any individual or entity to influence a decision or action in their favor.

• • Embezzlement: Misappropriating or illegally converting company funds or assets for personal gain.

• • Conflicts of Interest: Engaging in any activity, financial or otherwise, that puts personal interest in conflict with one’s professional duties and responsibilities.

• • Extortion: Obtaining money, property, or favors through threats or coercion.

• • Fraud: Making false or misleading statements to deceive others for personal gain.

• • Money Laundering: Concealing or disguising the illegal origins of money or assets.

• • Facilitation Payments: Offering or accepting small bribes to expedite routine governmental actions.

Our Commitment to Anti-Corruption:

H.S Cool Point is committed to the following:

• • Zero Tolerance: We have a zero-tolerance policy towards all forms of corruption. Any employee suspected of engaging in corrupt practices will be subject to disciplinary action, up to and including termination of employment and legal prosecution.

• • Continuous Improvement: We are committed to continuously improving our anti-corruption program through regular risk assessments, policy updates, and employee training.

• • Open Communication: We encourage all employees to report any suspected corruption, without fear of retaliation. We provide various confidential reporting channels to facilitate such reporting.

• • Third-Party Due Diligence: We conduct proper due diligence on all third-party vendors and partners to ensure they adhere to ethical business practices.

Employee Responsibilities:

All employees of H.S Cool Point are responsible for understanding and complying with this policy. This includes:

• • Understanding: Familiarizing oneself with the different forms of corruption and the company’s anti-corruption policies and procedures.

• • Reporting: Reporting any suspected instances of corruption to the appropriate authorities immediately, using the established confidential reporting channels.

• • Refusal: Refusing to participate in any activity that could be considered corrupt, even if pressured by others.

• • Disclosure: Disclosing any potential conflicts of interest to the company promptly.

• • Compliance: Adhering to all applicable laws, regulations, and company policies and procedures related to anti-corruption.

Reporting Procedures:

Employees are encouraged to report any suspected cases of corruption through the following channels:

• • Direct Supervisor: Reporting concerns directly to their supervisor.

• • Human Resources Department: Contacting the Human Resources department directly.

• • Anonymous Reporting Hotline: Reporting anonymously through the designated hotline or online reporting system.

Confidentiality and Non-Retaliation:

H.S Cool Point is committed to protecting the confidentiality of all individuals who report suspected corruption in good faith. No employee will be retaliated against for reporting suspected corruption in good faith.

Training and Awareness:

H.S Cool Point provides regular anti-corruption training to all employees to raise awareness, understand the policy, and equip them with the tools to identify and report potential corruption.

Investigations and Disciplinary Action:

Allegations of corruption will be promptly investigated by qualified personnel. Disciplinary action will be taken against any employee found to have engaged in corrupt practices, in accordance with the company’s disciplinary procedures and applicable laws.

Monitoring and Review:

The Anti-Corruption Policy will be reviewed and updated periodically to ensure its effectiveness. The company’s compliance with the policy will be monitored regularly.

Conclusion:

H.S Cool Point is committed to maintaining a culture of integrity and transparency. By working together, we can prevent corruption and ensure that our company operates ethically and responsibly.

Additional Information:

• • This policy is intended to be a general overview and may not address all aspects of anti-corruption.

• • Employees are encouraged to seek guidance from the Human Resources department or legal counsel if they have any questions about this policy or its application.

By implementing and adhering to this comprehensive Anti-Corruption Policy, H.S Cool Point can continue to conduct its business with integrity and ethical responsibility, contributing to a more fair and transparent marketplace.