Genius Honesty and Integrity Commitment

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Genius Honesty and Integrity Commitment

Genius upholds the principles of fairness, honesty, trustworthiness, and transparency to conduct business activities. In order to implement the "Code of Integrity Management" with the highest standards, it adopts a zero-tolerance policy to prevent corruption, bribery, monopoly, and unfair competition. Corruption includes bribery, facilitating payments, kickbacks, conspiracy, embezzlement, fraud, theft of property, and acts intended to improperly influence a third person or to obtain personal gains which will incur losses to the company. All directors and employees of Genius, as well as any third party who acts for Genius or on behalf of Genius for the purpose of business with Genius ("Business Partners"), should be aware of and abide by Genius anti-corruption regulations.

 
No Bribery
 

Genius prohibits offering or accepting bribes, facilitating payments or kickbacks. People who have business with Genius or act on behalf of Genius shall not provide benefits for the purpose of bribery, regardless of whether the provider or the recipient is a government official or an ordinary individual.

 
Avoidance of Conflict of Interest
 

Genius employees and those who provide services to Genius should take the initiative to avoid actual or potential conflicts of interest. If the conflict of interest cannot be avoided, the conflict of interest should be declared or notified to Genius. Dealing with Unavoidable Conflicts of Interest Genius will take appropriate measures when necessary, including adjusting job positions, work content or business relationships, so as to reduce such unavoidable conflicts of interest.

 
No Fraud
 

The personnel of Genius shall not, for the purchasing of illegal benefit of themselves or any third party, cheat or transmit false information to make people fall into mistakes during the disposition of property.

 
Anti-Monopoly and Anti-Unfair Competition
 

The commercial activities of Genius are in compliance with the relevant regulations of anti-monopoly and anti-unfair competition laws and regulations, and personnel of Genius are prohibited from violating relevant laws and regulations.

 
Selection and Management of Business Partners
 

The person responsible for selecting the Business Partners (regardless of a company or an individual) for Genius should conduct a proper evaluation of the Business Partners before selection so as to ensure that the Business Partners have a good reputation. Personnel responsible for managing, directing or supervising business contacts should pay attention to whether the business contacts comply with Genius ethics requirements and anti-corruption regulations, and report any violation in a timely manner.

 
Maintaining Record Integrity
 

All financial operations, including the reimbursement of expenses on gifts and entertainment, should be properly recorded. All related records, including invoices, expense records, and other business records, shall adequately represent the transaction. It’s not allowed to mislead facts, omit information, or falsify records or reports in any way.

 
Identity Protection and Retaliation Prevention
 

In order to establish Genius reporting procedures to discover, prevent and avoid major misconduct, and to encourage open communication with employees and related parties, whistleblowers can report by name or anonymously. Genius actually protects its employees or third parties who report and participate in the investigation. In order to avoid improper retaliation and treatment, the investigation is conducted in a confidential manner.

 
Whistleblowing System
 

Reports that are accepted by the task force will be assigned to the appropriate units for review. When the report is verified to be true, punishment and the recovery of improper benefits or legal responsibility will be carried out depending on the severity of the circumstances. Meanwhile, Genius will also implements anti-corruption education and training for employees. In order to enhance the concept of integrity and self-discipline, Genius continues to implement education and training on legal compliance. In addition to relevant seminars held from time to time, Genius also plan internal courses on the acknowledgement and compliance of key laws and regulations, including but not limited to employee ethic regulations, anti-corruption, internal material information updates and antitrust.

 
Reporting Channel
 

If Genius employees or its Business Partners are found to have accepted bribes, offered bribes, or violated honesty and integrity regulations, please report in time to the audit office email address as audit@gseo.com