Anti-Bribery & Anti-Corruption (ABC) Policy Statement

In maintaining good governance, Back & Forward HK LTD and its affiliated subsidiaries (the Company) strives to conduct its business and operations with high ethical standards and integrity.

The Company has a zero-tolerance policy against all forms of bribery and corruption by its directors, management, employees and any person/organization acting for the Company and on its behalf, and takes a strong stand against such acts.

The purpose of this policy statement is to:

set out the responsibilities of the Company, and of those who work for or provide services to the Company (including the Company’s service providers), in monitoring and enforcing the Company’s stance on bribery and corruption;

provide information and guidance on how the company expects those who work for the company to behave and how to recognize and address bribery and corruption issues; And how to raise concerns with the company, including any violations of this policy.

Definition

Bribery

Any act deemed to be an offense of giving or receiving ‘gratification’ under the MACC Act.

Offering, giving, receiving, or asking for anything of value in an attempt to illegally influence the decisions or actions of a person in a position of trust within an organization.

Corruption

Any act that would be considered an offense of giving or receiving ‘gratification’ under the MACC Act.

May also include acts of extortion, conspiracy, breach of trust, abuse of power, influence peddling, embezzlement, fraud or money laundering.

In recognition of this commitment, our management has implemented and maintained a comprehensive anti-bribery and anti-corruption program, including an Anti-Bribery and Anti-Corruption Policy (ABC Policy):

to prevent, detect and monitor bribery and corruption in the company’s business activities;

provides guidance to management, employees and individuals/organizations acting for and on behalf of the Company on how to deal with improper requests, bribery and other corrupt activities and issues that may arise in the course of business operations;
effectively manages the company’s key bribery and corruption risks;
and fully complies with applicable anti-bribery and anti-corruption laws and regulatory requirements.

Management, its employees and persons/organizations acting for and on behalf of the Company are strictly prohibited from directly or indirectly soliciting, accepting or offering bribes in connection with the Company’s business and operations.

The Company expects that; individuals/organizations acting on its behalf and on behalf of the Company are aware of and committed to the relevant portions of the Company’s ABC Policy and Whistleblowing Policy, and that they adhere to the ethical business standards that are also established, accept and agree to abide by. as described in the Supplier Code of Conduct when performing such work or services for or on behalf of the Company.

The Company will conduct due diligence to assess the integrity of potential individuals/organizations acting for the Company and on its behalf before entering into formalized relationships, to avoid dealing with such individuals who are known or reasonably suspected of corrupt practices, and will not conduct business transactions unless these suspicions are investigated and resolved.

Where a person/organization acting for and on behalf of the company subcontracts with another third party to provide services under the main/framework contract with the company, the subcontracting provisions should require the said person/organization to induce its subcontractors to Comply with Supplier Code of Conduct, ABC Policy and Company Whistleblower Policy.

Individuals/organizations acting for the Company and on behalf of the Company who have breached the Supplier Code of Conduct, ABC Policy, Whistleblowing Policy and relevant related legal requirements may be subject to penalties, including termination of contract by the Company. Further legal action may also be taken if the interests of the Company have been damaged as a result of non-compliance by said individuals and organizations.

Back & Forward HK Ltd

Flat 1/B, 28-32 Gage Street, Central Hong Kong (Company number 659186)

E-mail: forward@asia.com