Anti-Bribery and Anti Corruption Policy

Anti- Bribery and Anti-Corruption Policy of Q-Trade Corporation

Q-Trade Corporation is dedicated to upholding the highest standards of ethical business conduct. Our commitment to honesty, integrity, and transparency is fundamental to our success and reputation. In alignment with these principles, Q-Trade Corporation strictly prohibits any form of bribery and corruption within the organization and in its interactions with business partners, service providers, customers, as well as governmental agencies and instrumentalities.

It is the responsibility of every director, officer, and employee to prevent and counter bribery and corruption within Q-Trade Corporation by adhering to this ethical business conduct policy.

Key principles of our Ethical Business Conduct Policy:

1.Compliance with Laws and Regulations: All directors, officers, and employees must ensure that their actions comply with relevant laws and regulations regarding bribery and corruption.

2.Interactions with Public Officials: Any interaction with public officials must comply with applicable laws and regulations, as well as this policy. Suppliers and contractors are also expected to adhere to the same standards.

3.Gifts and Hospitality:  The policy acknowledges the customary exchange of gifts of minimal value in the ordinary course of business. However, caution must be exercised in giving or receiving business-related gifts or hospitality.

4.Prohibited Acts:The following acts are strictly prohibited:

    • Offering, giving, requesting, or receiving money, gifts, favors, benefits, or anything of value to influence decisions or gain unfair advantages.
    • Using official functions for personal gain.
    • Performing or neglecting official functions in exchange for any form of personal gain.
    • Any actions similar to those stated above.

5.Appropriate Handling of Allegations:

Any act, attempt, or allegation of bribery and corruption will be treated as serious offenses. Q-Trade Corporation will handle such cases promptly and in accordance with the Company Manual for Corporate Governance, Corporate Code of Conduct, Company Code on Employee Discipline, the Revised Penal Code, and other relevant laws and regulations.

6. Reporting Mechanism:

Employees are encouraged to report any act or attempt of bribery or corruption to the office of Chief Finance Officer, the Office of the Chief Operating Officer (COO), the Internal Audit Group, the employee’s immediate supervisor, or any other responsible officer. The Company Whistleblower Policy provides the procedure for reporting and ensures protection for whistleblowers.

7.No Retaliation:

Q-Trade Corporation ensures that no employee will face penalties or adverse consequences for refusing to participate in bribery, even if it may result in the loss of business for the company.

Failure to observe this Ethical Business Conduct Policy may result in administrative disciplinary action, without prejudice to any civil or criminal liabilities that may be incurred by the offending director, officer, and/or employee.