True IDC Anti-Bribery & Anti-Corruption Policy and Guidelines

True IDC implemented an anticorruption policy and related procedures, with the aim to inculcate good practices, raise awareness on all forms of corruption, and create an organizational culture under good governance and ethical business practices. This is in order to create confidence and meet the expectations of all stakeholders. Nevertheless, there challenges in anti-corruption efforts, which also included the governance body members to ensure the comprehensive implementation of the anti-corruption policy and procedures.

1. Offering or accepting gifts

Directors, management and staff must not offer or accept gifts that may influence business decisions.

2. Entertainment

Entertainments are allowed for the purpose of maintaining a business relationship, but must conform to business norms and do not have an influence on business decisions.*

3. Facilitation Payments

(1) True IDC prohibits the making of facilitating or expediting payments, both directly and indirectly, under any circumstances. This includes facilitation payments that are made under conventional business practices and payments to a third-party, in particular expediting payments made to state officials.

(2) Find alternatives or workarounds to eliminate the need for facilitation payments.

(3) If in a situation that there is no workaround or that facilitation payment is unavoidable, employees should inform their supervisor in order to agree to a solution.

4. Charitable donations and contributions

Charitable donations and contributions must be carried out through a transparent process. Donations and contributions, whether in the

form of money or other forms, must have procedures and disbursements that are clear and secure to ensure that they cannot be used as a channel for corruption.

5. Related Persons acting on behalf of True IDC

When nominating a third-party to represent True IDC, including agents and consultants acting on behalf of True IDC, make sure that all procedures comply with the following:

(1) Provide information and communicate to the representative to ensure they acknowledge and comply with the Anti-Bribery and

Anti-Corruption Policy of the True IDC.

(2) Communicate with the individual or entity, whether from the private or public sector, to ensure they acknowledge and comply

with True IDC’s Anti-Bribery and Anti Corruption Policy.

6. Political Contributions

True IDC allows the participation in political contributions, which must be conducted transparently and verifiably, in order to

avoid discrimination or appear to benefit both political parties and the organization. The principles are as follows:

(1) True IDC shall remain politically neutral, and not favor any political group.

(2) True IDC can provide support, whether in the form of money or assets to political parties but such actions

need to be transparent and not for the purpose of attempting to influence any improper exercise of functions, duties or judgment.

(3) Directors and employees have the freedom and the right to participate in political activities in a personal capacity, as

provided under the Constitution, but shall not refer to True IDC and shall not use any property, equipment or device owned by the organization to support such personal political involvement/activity.