ANTI-BRIBERY & ANTI-CORRUPTION POLICY

1. Purpose

New Media Holding Pte. Ltd. ("NMH") is committed to conducting business with integrity, transparency and honesty.

NMH has a zero-tolerance approach towards bribery and corruption and is committed to complying with all applicable anti-bribery and anti-corruption laws in every jurisdiction in which it operates.

This Policy establishes the standards expected of everyone acting for or on behalf of NMH and forms part of NMH's broader commitment to ethical business practices.

2. Scope

This Policy applies to: Directors and Officers, Employees, Consultants, Contractors, Freelancers, Agencies, Vendors and Suppliers, Influencers and Talent, Production Partners, Representatives and Agents, Any other individual or organisation acting on behalf of NMH.

Where this Policy is incorporated into a contract, purchase order or engagement letter, compliance with this Policy is a contractual obligation.

3. Our Commitment

Everyone covered by this Policy is expected to:

• conduct business honestly and ethically;
• comply with all applicable anti-bribery and anti-corruption laws;
• avoid actual or perceived conflicts of interest;
• refuse to offer, request or accept bribes or improper benefits;
• maintain accurate business records;
• promptly report suspected misconduct; and
• uphold NMH's reputation for integrity.

4. What is Bribery?

Bribery is the offering, promising, giving, requesting or accepting of anything of value to improperly influence a decision, obtain an unfair advantage or induce someone to improperly perform their duties.

A bribe may include, without limitation:

• cash;
• gifts;
• hospitality;
• travel;
• entertainment;
• employment opportunities;
• loans;
• discounts;
• sponsorships;
• charitable donations; or
• any other personal or business benefit.

5. Prohibited Conduct

No person covered by this Policy shall:

• offer or accept any bribe or kickback;
• make or receive secret commissions;
• offer anything of value to improperly influence a business decision;
• make facilitation payments;
• use third parties to make improper payments on NMH's behalf;
• conceal improper payments through false invoices or inaccurate records;
• misuse charitable donations or sponsorships to obtain business advantages; or
• knowingly engage with any person or organisation involved in corrupt practices.

6. Gifts, Hospitality and Entertainment

Reasonable business gifts and hospitality may be exchanged where they:

• are lawful;
• are modest and proportionate;
• are given openly and transparently;
• are infrequent;
• have a legitimate business purpose; and
• do not influence, or appear to influence, business decisions.

The following are prohibited:

• cash or cash equivalents;
• lavish or extravagant gifts;
• gifts or hospitality during active tenders or contract negotiations;
• gifts intended to secure an improper advantage; and
• any entertainment that could reasonably damage NMH's reputation.

7. Government Officials

Extra care must be exercised when interacting with government officials, regulators or public authorities.

No person acting on behalf of NMH may offer, promise or provide anything of value to improperly influence any governmental decision or obtain an improper advantage.

8. Third Parties

NMH expects all suppliers, agencies, consultants, talent, influencers, contractors and business partners to conduct business ethically.

Anyone acting on behalf of NMH must:

• comply with this Policy;
• comply with applicable anti-corruption laws;
• avoid improper payments;
• maintain accurate records relating to services provided to NMH;
• cooperate with reasonable compliance enquiries; and
• promptly notify NMH of any suspected breach of this Policy.

NMH reserves the right to decline, suspend or terminate relationships with any person or organisation that fails to comply with this Policy.

Where a supplier, agency, consultant, contractor, talent, influencer or other business partner engages employees, subcontractors, agents or representatives in connection with services provided to NMH, it shall ensure that such persons are made aware of and comply with this Policy or are subject to equivalent anti-bribery and anti-corruption obligations.

9. Conflicts of Interest

Business decisions must always be made in NMH's best interests.

Actual, potential or perceived conflicts between personal interests and business responsibilities should be disclosed promptly to NMH.

10. Books and Records

All financial transactions and business records relating to NMH must be complete, accurate and fairly reflect the underlying transaction.

False, misleading or incomplete records are strictly prohibited.

11. Charitable Donations and Sponsorships

Charitable donations and sponsorships must be made only for legitimate purposes and must never be used to obtain or retain business or secure an improper advantage.

12. Reporting Concerns

Anyone covered by this Policy who becomes aware of suspected bribery, corruption or unethical conduct involving NMH should promptly report the matter through NMH's designated reporting channels.

NMH will treat reports seriously and prohibits retaliation against any individual who raises a genuine concern in good faith.

13. Compliance

NMH may request reasonable information from employees, suppliers, talent, agencies and other business partners to verify compliance with this Policy.

Failure to cooperate with legitimate compliance enquiries may constitute a breach of this Policy.

14. Consequences of Non-Compliance

Failure to comply with this Policy may result in:

• disciplinary action;
• suspension or termination of employment or engagement;
• termination of supplier or service agreements;
• removal from NMH's approved supplier network; and
• referral to relevant regulatory or law enforcement authorities where appropriate.

15. Policy Review

NMH may amend this Policy from time to time to reflect changes in applicable laws, regulations and business practices.

The latest version of this Policy will be published on NMH's website.

Practical Guidance