Anti-Corruption Policy

Anti-Corruption Policy

Dong Nhat Information Technology Co., LTD (NTTNETWORKS) and member companies (VOIPMART, CLOUDPBX) support efforts to fight corruption in all its forms.

As part of our commitment, we do not allow and reduce corruption in our business operations to become more and more cleaner.

NTTNETWORKS with member companies and all of its employees oppose corrupt acts of any kind and firmly oppose bribery to promote good governance, economic development and social welfare in the places where NTTNETWORKS operates.

We are committed to operating ethically, in compliance with the law and professionally in accordance with the provisions of this Anti-Corruption Policy.

Policy applies to all people and activities of NTTNETWORKS. All partners and employees are required to read, understand, and adhere to this policy.

This policy is approved by the Board of Directors of NTTNETWORKS.

The focus of this Anti-Corruption Policy is as follows:

We prohibit our associates and intermediaries from giving, offering or accepting bribes, sharing payments or anything of value with any organization or person to obtain or improperly maintaining a business contract or operation, government approval, preferential taxes and preferential customs decisions or to secure any other false business advantage. Bribery is strictly prohibited, as well as illegal shared expenses or benefits or being unethical affects our reputation, revenue and business.

More specifically, we will not engage in or be involved in any of the following:

1.Bribery

Bribery is understood as bribery in all its forms, this includes offering, promising, giving, receiving, or soliciting funds to gain an illegal business advantage. Bribing another person through offering, promising, or giving a financial benefit or other benefit to solicit or reward allowing the person to perform a related illegal function or activity, or accepting that benefit is deemed to be performing an illegal function. Offering, agreeing to accept or accepting a bribe that results in an illegal act of the relevant function or activity is also considered a bribe. Accepting a bribe through offering, agreeing to accept or accepting a financial benefit or other benefit is considered an act of performing an illegal function or activity.

2.Political contributions

Promising, giving or calling for contributions to political parties, or organizations or individuals participating in politics as a form of concealment for bribery.

3.Charitable contributions

Promising, giving or calling for charitable donations or relating to charitable sponsorships as a form of hiding for bribery.

4.Sponsorship, Gifts, hospitality and accommodation

Offering or accepting gifts, entertainment or accommodation as a form of hiding for bribery.

5.The payments are for convenience purposes

Amounts, whether small or large, in the form of an offer, promise or gift of a financial benefit or other benefit intended to facilitate authorized operations, constitute bribery as well as violations and accordingly are prohibited acts.