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Anti-Commercial Bribery Compliance

UBTECH believes that commercial bribery violates the fundamental principles of the market economy, disrupts market order, and harms the healthy development of relationships between cooperating parties. It also corrupts social morals, erodes the integrity of corporate employees, and becomes a breeding ground for corruption and economic crimes. UBTECH adheres to the principles of fairness, integrity, and transparency in conducting business globally and maintains a "zero-tolerance" policy towards any form of commercial bribery.

UBTECH strictly prohibits any form of bribery during the course of business. Employees of UBTECH are prohibited from directly or indirectly promising, giving, receiving, or accepting money or any other thing of value to improperly influence the performance of the recipient's duties or actions, in order to obtain undue advantages in business dealings.

UBTECH demands that its employees comply with laws and regulations and UBTECH's code of professional conduct in their business dealings with partners, ensuring fairness, integrity, and transparency in the cooperation process, without any discrimination or deception. Employees are prohibited from accepting or soliciting property or seeking personal benefits from partners, and from using their positions to influence the selection and evaluation of partners, thereby granting "special treatment" to certain collaborators.

UBTECH is committed to improving and perfecting its anti-commercial bribery compliance systems, processes, and guidelines to reduce the risk of commercial bribery, further integrating integrity, transparency, and honesty as essential components of the corporate compliance culture. UBTECH's anti-commercial bribery compliance policies shall follow the anti-commercial bribery or anti-corruption regulations of the countries or regions where the business is conducted, and ensure that global operations strictly adhere to applicable anti-corruption and anti-commercial bribery laws and regulations. UBTECH's anti-commercial bribery compliance policies apply to all directors, managers, and employees of UBTECH, including its departments, subsidiaries, affiliates, and branches. UBTECH has joined industry compliance organizations such as the Sunshine Integrity Alliance and the Internal Control Association, actively participates in sharing and exchanging anti-commercial bribery management experiences in the industry, and has passed the anti-commercial bribery management system certification (ISO37001).

The Board of Directors and the Compliance Adherence Committee fully support anti-commercial bribery compliance management and provide resource guarantees for compliance construction. The company has established a compliance adherence system responsible for formulating and implementing special anti-commercial bribery compliance programs, promoting the construction and operation of the anti-commercial bribery compliance management system. The Compliance Adherence System includes an Audit Department, which is independently responsible for the supervision and investigation of commercial bribery and corruption cases, and carries out integrity education through official websites, WeChat Public Account, office systems, and supplier integrity visits, demonstrating UBTECH's determination to fight corruption and promote integrity.

UBTECH is dedicated to working with partners to build a "clean, honest, and transparent" business environment. If you encounter any anti-commercial bribery compliance issues or potential violations in your business dealings with UBTECH, you may report directly to the UBTECH Compliance Audit Department. UBTECH ensures that reports made in good faith will not result in retaliation.

Management Commitment Statement of Anti-commercial Bribery