1. vivo's Anti-Corruption Policy

vivo Mobile Communication Co. Ltd. and its subsidiaries and affiliates (hereinafter “vivo” or “Company”) are committed to comply with all applicable anti-corruption and anti-bribery regulations to ensure that vivo's business is conducted in a socially responsible manner.

vivo's Policy is clear:

vivo does not pay or accept bribes.

This Policy applies to all individuals working at vivo at all levels and grades, including directors, officers, senior managers, employees (whether permanent, fixed-term or temporary). This Policy also applies to consultants, contractors, seconded staffs, casual workers and agents, channel partners or any other person working for, or on behalf of vivo wherever located. All aforementioned must act in line with vivo's vision requirements and core values when engaging in any business with vivo. vivo expressly prohibits bribery and corruption in all business dealings - whether with government or public officials or with business partners in private sector – everywhere where applicable.

2. Areas of Application/ Principles

Bribery and corruption issues can arise in many types of transactions. Certain activities can raise particular compliance concerns and are subject to specific requirements. These areas include but not limited to facilitating payments, donations, gifts and entertainment, company-sponsored activities, political contributions, cooperating with third parties and others.

2.1. Facilitating/ “Grease” Payments

vivo prohibits facilitating payments whether they are in cash or “in-kind.” The Company also prohibits making facilitating payments through a third party, and third parties are prohibited from making facilitating payments on vivo's behalf or in connection with the vivo's business, with or without vivo's knowledge.

2.2. Political or Charitable Donations

vivo's prohibits contributions directly or indirectly to political parties, to candidates for political office and to political party officials. Charitable donations are always subject to the prior review and written approval of the relevant department of vivo.

2.3. Gifts, Hospitality and Entertainment

vivo strictly prohibits offering, providing or accepting gifts or entertainment that can appear or be interpreted as bribes or other improper forms of compensation, payment or inducement in exchange for or to influence improper acts, or as a gratitude after-the-fact.

The giving or receipt of gifts and hospitality is not prohibited, if certain requirements are met, which are always subject to the prior review and written approval of the relevant department of vivo.

2.4. Cooperation with Third Parties

Cooperation may happen and be necessary as part of the ordinary business for vivo either with parties from the private sector (e.g. suppliers, consultants) or parties from the public sector (e.g. officials, governmental/ public institutions).

Therefore, vivo and any of its employees must only engage with Third Parties if:

· there is a legitimate need for the services or goods that they provide;

· the services and goods are priced at no more than market value;

· the procurement process has been followed;

· there is a written contract; and

· the receipt of such services or goods is documented.

Engagement of Third Parties must never be used to create an incentive or reward for facilitating the sale of vivo products improperly or securing any improper business advantage for vivo. Procurement must follow the established and monitored processes regarding the election, certification/ screening, negotiation and contracting of Third Parties and must document the process. Any business transactions with officials or companies wholly or partly owned by an official or their close relatives or business associates must be approved in advance in writing by the relevant department of vivo.

3. Reporting of Issues

Every employee or partner of vivo is encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. These should be raised contacting relevant vivo legal or other representatives of vivo.

vivo aims to encourage openness and will support anyone who raises genuine concerns in good faith under this Policy, even if they turn out to be mistaken.

vivo will not tolerate retaliation against any employee who reasonably and in good faith raises concern or asks a question about business practices or compliance with applicable laws or this Policy using the vivo reporting channel (integrity@vivo.com).

4. Consequences of Infringement

Any employee who breaches this Policy, if it constitutes a crime, may face labour law consequences as well as external prosecution. vivo reserves its right to terminate our contractual relationship with contractual parties if they breach this Policy.