TYCOONS
Clues notice or complaint items

           1 Find the bribery and corruption is related with the Company, either directly or indirectly. For example: discovery company personnel giving / accepting bribes to/from governmental officers or private entities personnel.

           2 Find a job procedure is not executed in accordance with the company regulations or affect the internal control system of the Company.

           3 Find the behavior cause the loss of profits or reputation of the Company.

           4 Find illegal, unethical conduct or breach of the code of conduct.

Complaint window of the bribery and corruption, channel of clues notice

           Employees or complainant must specify the details of clues or complaint of bribery and corruption, and provide contact names, address and telephone number to internal audit department.

Protection and confidentiality

          The Company will protect the rights of the complainant. Person who receives the personal information of complainant, the evidence, and the information provided by the complainant has the custody to keep its confidential. The information are prohibited to reveal unless the disclosure in accordance with the law.

Investigation and punishment procedures

           1 After received clues, management and the Board of audit committee take the responsibility to investigate the truth.

           2 During the investigation, management and the Board of audit committee may appoint any representatives (internal auditors) to report the progress of investigation results to complaints regularly.

           3 After completed the truth of the investigation, the company will inform the complainee if the information or evidence are reasonable and credible. The complanee has the rights to prove its innocence by providing some more evidences and information.

           4 If the complainee violates the anti-bribery corruption policy and conduct code of the company, it will be punished in accordance with the policy and regulation of the Company. If the bribery and corruption behavior violate the law at the same time, it may be subject to punishment of laws regulations. The punishment of company discipline will be judged by the Board of audit committee as an end.

           When the event of complaints occur, management and the Board of audit committee are responsible for receiving complaints, surveying the information, investigating the truth, joining the examination, making an appropriate punishment, and reporting to the Board of directors.

Dissemination of anti-bribery and corruption policy

           In order to all employees of the Company understand the policy of anti-bribery and corruption, the Company will perform the following items:

           1 The Company will disclose the anti-bribery and corruption policy through the company website, Annual Registration Statement (56-1), etc.

           2 The Company will have the training courses of the anti-bribery and corruption policy for all new employees.

           3 The company will review the implementation of anti-bribery and corruption policy every year.

Effective date: November 13, 2014.