Anti-corruption Policy for xFusion Partners V1.0

xFusion Digital Technologies Co., Ltd. (hereinafter referred to as "xFusion" or "the company") upholds the principles of conducting business with integrity, maintaining a strong sense of business ethics, and complying with all applicable laws and regulations. xFusion applies a "zero-tolerance" approach towards bribery and corruption.

xFusion requires all its partners, including suppliers, service providers, subcontractors, consultants, sales partners, and other partners, to comply with all applicable anti-corruption laws and regulations, generally-accepted business ethics, and requirements arising from the Anti-corruption Policy for xFusion Partners ("this policy"). Specifically, when partners are providing products and services to xFusion and fulfilling their contractual obligations, or providing products and services to xFusion customers or other third parties and fulfilling their contractual obligations on behalf of xFusion, they shall comply with and uphold the following requirements.

1. Partners are forbidden from engaging in any form of bribery or corruption, including but not limited to:

• Partners are forbidden from offering bribes to public officials, counterparty stakeholders, or stakeholders that can exert influence over a transaction, for the purpose of helping xFusion obtain or retain business.

"Bribe or Bribery" in this policy refers to the act of offering money or anything of value of any form with a corrupt intent. Such bribes may include cash, cash equivalents (such as gift cards and precious metals), inappropriate gifts, tourism arrangements and hospitality, and improper charitable contributions and donations.

The public officials in the policy include individuals who perform duties on behalf of government entities; employees of government agencies, state-owned or state-controlled enterprises, or international organizations; candidates or members of political parties; and other personnel who perform public services according to the law. When engaging with public officials, xFusion partners must be mindful of adhering to applicable laws, the honesty and integrity requirements for public officials, and this policy.

• Any xFusion employee is forbidden from receiving bribes or offering bribes (see Corporate Anti-bribery Policy for details). If any xFusion employee attempts to utilize, aid, abet, induce or conspire with a xFusion partner to engage in bribery, the partner shall explicitly refuse to participate in this act and voluntarily report it to xFusion.
• Partners are forbidden from offering bribes or improper interest to any xFusion employee or their families in any form.

2. Partners shall avoid taking any improper action that may lead to joint and several liability of xFusion, and shall avoid their partners from taking any improper action that may lead to joint and several liability of xFusion.

3. Partners shall keep books and records in an authentic, accurate, and complete manner. False, misleading, incomplete, inaccurate or artificial entries in the books and records are prohibited. Partners shall not establish or use any undisclosed or unrecorded accounts.

4. Partners shall establish an effective compliance management system, and implement anti-corruption requirements in their business activities and processes from end to end. To ensure better compliance with applicable laws and regulations, and xFusion's anti-corruption requirements, partners shall pass on xFusion's anti-corruption requirements to their employees and partners, and regularly review the implementation of these requirements.

5. Partners shall coordinate with xFusion. To ensure that our Partners always abide by the law, ethics, and xFusion's anti-corruption requirements, xFusion shall have the right to conduct proper due diligence of its partners, and implement corresponding control procedures. Partners shall provide authentic, complete, legitimate, and valid documents, and shall not hide any information that may negatively impact xFusion's legitimate interests.

6. Partners shall report employees who have interest conflict with xFusion and address this conflict. Employees with interest conflict includes xFusion employees who invest or assume a position in a third-party, xFusion employees whose immediate relative assumes a business post related to xFusion in a third-party, formal xFusion employees who assume a business post related to xFusion in a third-party within 2 years after termination with xFusion, formal xFusion employees who were expelled, dismissed, persuaded to resign or leaved voluntarily because of violation of business standard, and assume a business post related to xFusion in a third-party.

If any Partner violates this policy or makes any false or fraudulent statement, representation, or warranty, or xFusion has reasonable grounds to believe that the partner has committed such an act, xFusion has the right to suspend or terminate its partnership with the partner immediately upon issuing a written notice and reserves the right to hold the Partner legally liable.

If you have any questions about this policy, or if you know of or suspect a violation of applicable anti-corruption laws and regulations, or of xFusion's anti-corruption policies and requirements, by any partner or xFusion employee, please notify us by writing to BCGComplain@xfusion.com. xFusion will launch an investigation and protect the whistleblower from threats or retaliation.

"xFusion" in this policy refers to xFusion Digital Technologies Co., Ltd and its directly or indirectly controlled subsidiaries worldwide.

In the event there is any inconsistency between this Policy and local laws and regulations, whichever has stricter requirements shall prevail.

This document takes effect since its issue date, and will remain valid for 3 years.