Anti-Fraud, Bribery, and Corruption Policy

  1. Purpose

This policy sets out the principles and standards for preventing fraud, bribery, and corruption within QBIC TECHNOLOGY CO., LTD. (the “Company”). This policy applies to all employees, directors, officers, contractors, consultants, agents, and any other third-party representatives acting on behalf of the Company.

  1. Scope

This policy applies to all activities and operations of the Company in Taiwan and any other jurisdictions where the Company operates.

  1. Definitions
  • Fraud: Any intentional act or omission designed to deceive others, resulting in the victim suffering a loss and/or the perpetrator achieving a gain.
  • Bribery: The offering, giving, receiving, or soliciting of something of value to influence the actions of an official or other person in discharge of a public or legal duty.
  • Corruption: Abuse of entrusted power for private gain.

4. Policy Statements

4.1 Zero Tolerance: The Company has a zero-tolerance approach to fraud, bribery, and corruption.

4.2 Compliance with Laws: The Company complies with all applicable anti-fraud, bribery, and corruption laws, including the Taiwan Anti-Corruption Act and any other relevant legislation.

4.3 Prohibited Activities: The following activities are strictly prohibited:

        • Offering, giving, or receiving bribes, including facilitation payments.
        • Engaging in any form of fraud, embezzlement, or theft.
        • Participating in corrupt practices in dealings with public officials or private individuals.
        • Failing to report any known or suspected instances of fraud, bribery, or corruption.

5. Responsibilities

5.1 Employees: Employees must adhere to this policy, report any suspicious activities, and cooperate with investigations.

5.2 Management: Management is responsible for implementing this policy, ensuring compliance, and providing training to employees.

5.3 Internal Audit: The Internal Audit function will conduct periodic reviews to ensure compliance with this policy and report findings to the Board of Directors.

6. Reporting Procedures

6.1 Whistleblowing: The Company encourages employees to report any concerns or suspicions of fraud, bribery, or corruption through the designated whistleblowing channels.

6.2 Confidentiality: Reports will be handled confidentially, and the Company will protect whistleblowers from retaliation.

7. Investigation and Disciplinary Action

7.1 Investigation: All reported cases of fraud, bribery, or corruption will be promptly and thoroughly investigated.

7.2 Disciplinary Action: Employees found to be involved in fraud, bribery, or corruption will face disciplinary action, up to and including termination of employment.

8. Training and Awareness

The Company will provide regular training and awareness programs to employees on anti-fraud, bribery, and corruption practices.

9. Monitoring and Review

The Company will regularly monitor the effectiveness of this policy and review it annually to ensure its continued relevance and effectiveness.

10. Approval and Amendment

This policy is approved by the Board of Directors and may be amended at any time to reflect changes in the law or the business environment.