Anti-Bribery & Corruption Policy

Effective Date: 1 January 2025

Version: [01.2025-ALTAS/ABC Policy]

1. PURPOSE

ALTAS is committed to the highest standards of ethical conduct and professional integrity. This Anti-Bribery & Corruption (ABC) Policy reaffirms our zero-tolerance approach to bribery and corruption, in compliance with Vietnamese law and international frameworks such as the UK Bribery Act, the U.S. Foreign Corrupt Practices Act (FCPA), and the UN Convention Against Corruption.

ALTAS complies with all applicable anti-bribery and anti-corruption regulations both within Vietnam and in Every jurisdiction where we operate. Accordingly, this Policy sets forth the company’s position on all forms of bribery and corruption—including interactions with third parties, management of conflicts of interest, provision and receipt of gifts or hospitality, and whistleblowing procedures.

The primary aim of this Policy is to provide clear guidance to employees and business partners for identifying, preventing, and responding to instances of bribery or corruption, while helping them understand their roles and responsibilities in maintaining ethical operations.

To ensure transparency and accessibility, this Policy must be visibly posted in all Altas workspaces and published on the company’s official website for the benefit of employees, clients, and business partners.

2. SCOPE

This Policy applies to:

• All employees, partners, and directors

• Contractors, consultants, and interns

• Clients, suppliers, and third-party intermediar

• Subsidiaries and affiliated entities under ALTAS’s control

3. CORE PRINCIPLES

• Zero tolerance for bribery, facilitation payments, or any form of corruption

• Personal responsibility: Every employee is accountable for upholding this Policy

• No exceptions: Local customs or business pressures do not justify unethical conduct

• Transparency: All transactions must be accurately recorded and auditable

4. INDUSTRY-SPECIFIC RISKS

As a provider of legal, accounting, and tax services, ALTAS faces elevated risks in:

• Client onboarding: Potential exposure to money laundering or tax evasion

• Government interactions: Risk of undue influence in audits or legal proceedings

• Fee arrangements: Potential misuse of billing to disguise improper payments

• Referral networks: Risk of undisclosed commissions or kickbacks

5. PROHIBITED CONDUCT

ALTAS prohibits:

• Offering or accepting bribes, kickbacks, or facilitation payments

• Misrepresenting services or inflating invoices

• Assisting clients in unlawful tax avoidance or fraudulent schemes

• Using legal privilege to conceal unethical conduct

6. GIFTS, HOSPITALITY & ENTERTAINMENT

Permitted only if:

• They are modest, infrequent, and not intended to influence

• They are disclosed and approved in line with internal thresholds

• They are not offered during sensitive engagements (e.g., audits, litigation)

7. THIRD-PARTY INTEGRITY

• Conduct risk-based due diligence before engagement

• Include anti-bribery clauses in contracts

• Monitor third-party conduct throughout the relationship

• Terminate relationships with non-compliant partners

8. CLIENT ACCEPTANCE & RISK SCREENING

• Enhanced due diligence for high-risk clients (e.g., PEPs, offshore entities)

• Refusal of engagements that pose unacceptable ethical or legal risks

• Documentation of all client risk assessments

9. TRAINING & AWARENESS

• Mandatory onboarding and annual refresher training

• Tailored modules for high-risk roles (e.g., client-facing, finance, legal)

• Regular updates on emerging risks and regulatory changes

10. REPORTING & WHISTLEBLOWING

• Channels: contact@altas.vn, hotline +84 28 627 09600, anonymous portal: https://altas.vn/lien-he

• Confidentiality and non-retaliation guaranteed

• Prompt, impartial investigation of all reports

11. MONITORING & ENFORCEMENT

• Periodic audits of client files, billing practices, and third-party payments

• Spot checks and compliance reviews

• Disciplinary action for violations, including termination and legal referral

12. LEADERSHIP COMMITMENT

ALTAS’s leadership is responsible for:

• Setting the ethical tone from the top

• Ensuring adequate resources for compliance

• Leading by example in all business dealings

Approved by: Altas Coporation Leadership

Date: 1 Jan 2025

Policy Owner: Altas Corporation