Anti-Bribery and Corruption Policy

Purpose

The purpose of the Anti-Bribery and Corruption Policy (“Policy”) is to establish the anti-bribery and corruption policies of Ekmob Mobile Business Systems and Technologies Inc. and its affiliated companies operating domestically and internationally (“Ekmob Inc.”).

Scope

The Anti-Bribery and Corruption Policy applies to:

• All employees of Ekmob Inc., including the Board of Directors,
• Companies and employees providing goods and services, including suppliers, consultants, attorneys, external auditors, and other persons or entities acting on behalf of Ekmob Inc. (business partners).

This Policy is an integral part of:

• Corporate Governance Principles, approved by the Board of Directors and disclosed to the public,
• Ekmob Inc. Code of Business Ethics,
• Human Resources Practices.

Definitions

• Corruption: The misuse of the authority vested in a position, directly or indirectly, for any kind of personal gain.
• Bribery: An agreement in which a person acts against their duties by soliciting, accepting, offering, or promising benefits (directly or through intermediaries) to perform, refrain from, expedite, or delay a specific action related to their responsibilities.

Bribery and corruption can manifest in various forms, including:

• Cash payments,
• Political or other donations,
• Commissions,
• Social benefits,
• Gifts or hospitality,
• Other benefits.

Roles and Responsibilities

The implementation and updating of the Anti-Bribery and Corruption Policy fall under the authority, duties, and responsibilities of the Board of Directors. This includes:

1. The Corporate Governance Committee providing recommendations to the Board for establishing an ethical, lawful, reliable, and controlled working environment.
2. Senior management assessing risks and establishing control mechanisms in accordance with the principles set by the Board.
3. Relevant departments, including Audit, Legal, Accounting, and Investor Relations, ensuring Ekmob Inc.’s operations comply with legal regulations and corporate policies.
4. Establishing mechanisms for reporting, investigation, and enforcement in cases of policy violations.

Employees of Ekmob Inc. are responsible for:

• Adhering to the policies established by the Board,
• Managing risks effectively within their area of responsibility,
• Working in compliance with applicable laws and Ekmob Inc. practices,
• Reporting any behaviors, actions, or practices contrary to the Policy to the Board.

Firms Providing and Receiving Goods and Services

Suppliers, service providers, and business partners are required to comply with the Policy and other relevant legal regulations. Relationships with parties failing to meet these standards will be terminated.

Selection of Firms and Business Partners

When selecting firms and business partners, criteria such as experience, financial performance, technical competence, ethical standards, and positive reputations are evaluated. Relationships with entities associated with bribery or corruption, regardless of meeting other criteria, are not pursued. Thorough research and evaluations must be conducted prior to engaging in business relationships.

Agreements with Firms and Business Partners

Agreements and contracts with compliant firms and business partners must include:

• Full adherence to the principles outlined in the Policy and related regulations,
• Regular training and awareness programs for their employees,
• Provisions ensuring employees report any violations.

Failure to comply may result in the termination of agreements or partnerships.

Policies and Procedures

Bribery and Corruption

Ekmob Inc. opposes all forms of bribery and corruption. Offering or accepting bribes under any circumstances is strictly prohibited. Relationships with third parties attempting to engage in bribery or corruption with Ekmob Inc. must be discontinued.

Gifts

Gifts offered or received must be transparent, unconditional, and in good faith. Acceptable gifts and their registration procedures are detailed in the Ekmob Inc. Code of Business Ethics Gift Policy. Symbolic and low-value gifts are permissible, but regular gift acceptance is discouraged. Employees must notify HR and upper management of accepted gifts.

Facilitation Payments

No facilitation payments are permitted to expedite or secure routine processes with government agencies (e.g., permits, licenses).

Accurate Record Keeping

Ekmob Inc. complies with legal obligations regarding its accounting and record-keeping system. All accounts, invoices, and documents relating to third-party interactions must be complete, accurate, and securely maintained.

Training and Communication

The Policy is communicated to employees and accessible via www.ekmob.com. Training programs designed by HR, Audit, and Legal departments are mandatory for all employees to enhance awareness.

Reporting Policy Violations

Employees or representatives suspecting a violation of the Policy must report it to the Board. Reports are kept confidential, and employees are protected from retaliation for good-faith disclosures.

Consequences of Policy Violations

Policy violations are reviewed by the Board, and necessary sanctions are applied for non-compliance. Contracts with firms or individuals violating the Policy may be terminated without exception.